 All right, everybody it's two minutes after the hour so we're going to go ahead and get started. I hope everybody can hear me okay. If you cannot, you can submit a message to us quickly and we can check the audio. I am Shelby Mathis. I'm the Small Business Ombudsman here at the Consumer Product Safety Commission and thank you for signing up and attending this webinar. Our topic for today is going to be soft infant and toddler carriers and sling carriers. Before we get started, I just want to do a little bit of an intro if you've not used GoToWebinar before. On the right hand side of your screen is a control panel and it's got a few options there. The only ones that I really want to highlight for you is the questions section where you can submit questions throughout the webinar. We do have a colleague of mine, Will, who's here fielding questions and we've also got some internal staff that are here that are experts in this field that are happy to field questions as well so please submit those as I go through the material and you think of the questions. You can just type them into the questions box. Also in your handout section on the right hand side of the screen, you'll see a PDF version of the slides today. As I go through the slides you'll notice that some of them have hyperlinks and you won't be able to click on them from your screen because you're actually looking at a picture of my screen but in the handout on the right hand side of your screen that PDF is going to have that link for you and you're able to keep those slides for yourself and access the hyperlinks that way. So with all that and one quick disclaimer which is that this presentation was prepared by me. I'm a CPSC staff member and the views expressed here may not necessarily reflect the views of the commission. I think we are ready to get started. So the presentation agenda for today. First we're going to start out by defining carrier types because we are touching on two different types of carriers here. Soft infant and toddler carriers and I put in an abbreviation there, SITC. You're probably going to hear me use that pretty frequently. We internally use that because saying five words in sequence very frequently gets a little old so if you hear me say SITC I'm talking about a soft infant and toddler carrier. So we're going to talk about those and define those and then we're going to talk about sling carriers as well. So many times you're going to see the requirements that apply to both of those systems combined and if there are conflicting or contrasting requirements then I'll highlight that as well. And during defining carrier types we're going to do a fun interactive thing which I hope you guys will like which is actually looking at pictures of products that are on the market and you guys guessing whether or not they would fall under the SITC or the sling carrier standard. And you guys are probably experts out there listening to the webinar so I'm sure you're all going to get 100% but hopefully that's a fun part of defining carrier types for everybody. After we define the carrier types I'm going to talk about the labeling and instructional literature requirements that apply to both SITCs and sling carriers and then we're going to go through the testing requirements and that'll be the chemical testing requirements and then the physical and mechanical testing requirements that apply to both of these carrier types and there will be a demo video on one of the tests that apply specifically to sling carriers. Then I'm going to talk about children's product certificate when you need to have one, what one looks like and we'll even go through the actual sections in a children's product certificate or a CPC and show you what would normally go into the list of testing that would apply to these two types of carriers that you need to keep in your certificate. I'll highlight two recall examples towards the end and then I'll touch on CPSC business resources that will hopefully help you answer questions going forward and then as time allows and I do want to make sure we end on time we'll have a short Q&A session so again as you have questions please feel free to submit those using the right hand side of your screen. Alright, first up let's take a look at soft infant and toddler carriers. Now SITCs are covered under our reg and the list or the reg itself is listed there on your screen, 16 CFR part 1226. As kind of a little bit of an overview or an introduction, when I refer to the CFR that's a regulation. That's something that came from our government agency and that is the mandatory requirement that you have to make sure you comply with on these carriers. Most of the time and certainly in the case of soft infant and toddler carriers and sling carriers that we're going to talk about today, our regulation is actually incorporating what used to be a voluntary standard but is now a mandatory standard and for SITCs and slings those both came from ASTM. So when you see me refer to CFR that's our regulation. When you see an ASTM reference that is what used to be the voluntary standard but is now a mandatory standard for this product because our regs refer you straight to the ASTM documents. So I just wanted to try to clear up any confusion there. So SITC's definition states as follows. SITCs are a product normally of sewn fabric construction which is designed to contain a full term infant to a toddler generally in an upright position in close proximity to the caregiver and I've highlighted those underline and bolded sections because we're going to contrast that to sling carriers in just a second. In general, children are going to weigh between 7 and 45 pounds in an SITC and these products may be worn on the front, the side or the back of a caregiver with an infant either facing towards or away from the caregiver. And SITCs are normally worn by a caregiver with the child positioned in the carrier and the weight of the child and carrier suspended from one or both shoulders of the caregiver. So when we're going through some of the examples, the shoulder straps might be indicative of an SITC but we'll see as we go through some examples. Alright, so we just defined an SITC, let's define a sling carrier and again here, our reg is the Code of Federal Regulations Part 1228 and this is a new final rule from our agency that is becoming effective on sling carriers that are manufactured on or after January 30th of 2018. So for sling carriers that are being made right now, there is only a voluntary standard that would apply to sling carriers for those manufactured on or after that date on your screen in January of 2018. This becomes a mandatory standard and you have to make sure that you comply. So the definition for sling carriers is a product of fabric or sewn fabric construction which is designed to contain a child in an upright or reclined position while being supported by the caregiver's torso. So again, I've highlighted some of the similar terms from SITC and slings and some that are a little bit different in the definition of sling carriers versus SITCs. For slings, in general, a child is going to weigh between a full-term birth weight and 35 pounds and slings very similar to SITCs can be worn on the front, the hip, or the back with the child facing towards or away from the caregiver or in a reclined position on the front only of the caregiver and that reclined ability is unique to slings. A note on slings, and this is from the ASTM standard, F290715. Slings generally consist of a variety of unstructured designs ranging from a hammock-shaped product suspended on the caregiver's upper torso to a long length of material wrapped around the caregiver's body. Alright, so let's take a look at some pictures because we wouldn't want to start polling you guys and asking you to guess what things were without providing some examples first. So before I get started, a little disclaimer. The photos that are shown here are just meant for educational or illustration purposes and not meant to be an endorsement of any kind of product from our government agency. But examples of soft infant and toddler carriers, you can see three on your screen and I tried to select some variety in terms of which way the children were facing and how the item was being worn. So on the left-hand side of your screen, you can see the caregiver is wearing an SITC with the child facing towards the caregiver and they're wearing the child on the front. The picture in the middle, we've got what appear to be twins, although we don't know, they could be siblings. The child on the front is facing the caregiver and the child on the back is facing the caregiver, so that's a front and a back wear on SITCs. And on the right-hand side of the screen, we have a lady that's wearing a child that's facing away from her. So three examples of soft infant and toddler carriers here. Let's do the same for sling carriers and again, same disclaimer. The sling carriers that are shown here are just for illustration purposes and not meant to be any kind of endorsement of any product. So on the left-hand side, we've got a pouch sling and that child is kind of in a reclined position but facing towards the caregiver. The second sling is a ring sling which is kind of demarcated by the two rings that are used to secure the length of fabric and that child is facing the caregiver. And then we've got two examples of wrap and wrap-like slings. One where the child is facing towards the caregiver and one where the child is facing away from the caregiver. So what isn't a soft infant and toddler carrier or a sling carrier? Because we do get a lot of questions in our office on things that are carrier systems but don't fall under either of these two categories. So on the left-hand side of the screen, we've got frame child carriers. Those do not, they are not considered SITCs or sling carriers. They are regulated by our agency and they have their own requirements and I've highlighted that actually right below frame child carriers. Our reg is 1230 and the ASTM standard that's been incorporated as a mandatory one is 254914A. And that frame carrier you can actually see has quite a hard frame associated with it. So that's a calling card of frame child carriers. On the right-hand side of the screen is a handheld infant carrier which we also regulated our agency. And the reg that we have that regulates it is 16 CFR part 1225 and that incorporates ASTM 2050-13A. Which was a voluntary standard that became a mandatory standard for handheld infant carriers. Alright, so hopefully this is a fun part of the webinar today. I'm going to see if you guys can tell the difference between sling carriers and soft infant and toddler carriers. So on your screen right now you're taking a look at something that's either a sling carrier or an SITC. And I'd like for you to tell me whether or not you think it falls into either category. So I'm going to post a question on your screen and I want you to guess what that photo showed. I'm going to give you guys a few seconds to vote. Thank you everybody for voting. You're all voting very quickly. Alright, and I'm going to go ahead and close the poll and let's see what we as a group thought the answer was. Looks like pretty overwhelmingly we thought the answer was that that was a sling carrier. Let's see if everybody was right. You guys were absolutely correct that was a sling carrier. So I wanted to start out with an easy example. Clearly I did. Let's move to the next carrier system. I want you guys to tell me whether or not that's a sling carrier or a soft infant and toddler carrier. And in this example we have a gentleman wearing a child and the child is facing towards him but he's wearing it on the back. So do we think that's a sling or an SITC? Alright, and you guys are fast on voting. So I'm going to go ahead and close this poll and let's see what we thought that actually was. Overwhelmingly you guys think that that's a sling carrier. Let's see if you're correct. You are correct. That's a sling carrier. Let's move to the next example and if you will tell me whether or not you think that's an SITC or a sling. And thank you everybody for getting your votes in so quickly. Let's see what we as a group thought the answer was. Overwhelmingly you guys think that that is a soft infant and toddler carrier and you are correct and you can actually see the shoulder straps there that are crossing at her back. Alright, next example. What do we think these are? Are these slings or are they soft infant and toddler carriers? Alright, and I'm going to give you guys a little bit of time to guess on the photo with the three ladies wearing the children. And let's see what we as a group thought these three ladies were wearing. And as a group you guys thought about three quarters of you thought that these are slings. So let's see if you're correct. And these are sling carriers. You can see that those are, they appear to be long lengths of fabric tied in similar ways across all three individuals. So what about this gentleman? Is he wearing a sling carrier or a soft infant and toddler carrier? And you can see the child is facing away from him. And I thought this poll would be useful because even when I was first introduced to these products I had trouble depending on how complex they were and telling the difference. But you guys seem to be pros at this. Let's see what we as a group thought this gentleman was wearing. And everybody thought that this was a soft infant or toddler carrier. And you guys are correct. That's an SITC. Alright, what about this gentleman? And as I understand it, this may be a metai and this child is being worn on the back of the caregiver facing towards the caregiver. So what do we think in terms of sling or soft infant and toddler carrier on this product? I should have warned you. They're going to get a little bit more difficult as we go through. But you guys, you're building up momentum. I'll give you guys a few more seconds to get your votes in. Alright, let's see what we thought this was. And overwhelmingly, folks thought this was a soft infant and toddler carrier and you guys are correct. That is a soft infant and toddler carrier. Alright, what about this lady who's got a child facing towards her? She's wearing it on the front. What do we think this is? And you guys are quick. You seem to know all the right answers too. This is a good sign. Alright, I'm going to close the poll and it looks like 100% of you thought this was a soft infant and toddler carrier. And you are correct. This is a soft infant and toddler carrier. Let's take a look at the last item. And what kind of carrier system do we think this is? Alright, and everybody's gotten their votes in, it looks like. And I go ahead and close the poll and let's see what as a group we thought this carrier system was. 98% of you thought it was a sling carrier. And you are absolutely correct. Alright, well now that we've defined carrier system types, and thank you to everybody for participating in that polling, let's get into the requirements that apply to both SITCs and slings. Now that we know what they are and we can identify them. So I'm going to start with SITCs, soft infant and toddler carriers, on marking and labeling. You need to make sure that your marking and labeling is permanently on the product and the packaging. And that's actually a requirement from the ASTM F223614, the mandatory standard. The things that need to be included in terms of marking and labeling are a manufacturer, distributor, or seller name, and a place of business, such as city, state, and mailing address, including a zip code, and a telephone number. And the requirement that the telephone number be permanently put onto an SITC is actually from our Durables Reg, which is 16 CFR 1130.4. The ASTM standard has an OR telephone number. However, incorporating it with our Durables standard, the telephone number needs to be permanently on the product itself. So code or mark, identifying the date, needs to be on the product, and month and year minimum need to be part of that identification. We need to be able to tell the month and year at a minimum of manufacture of the SITC. And a bachelor run number, if you as a manufacturer are actually using that, and that's part of the CPSIA tracking information requirement, which I've got a hyperlink there that you can see in your handout. It'll take you to that requirement. If you don't use batches or run numbers, that's fine. No need to create a bachelor run system to put that on your product, but if you do, that should be included permanently on the product. In terms of informational statements, these also need to be included with the product. You need to let the consumer know how to assemble, how to use, how to maintain, and how to clean the product. And you also need to include applicable warnings, which we're going to get into in just a second. And also last thing to remember here on instructional statements for soft infant and toddler carriers where a child can be worn facing towards or away from the caregiver, you need to include a statement that says that a child must face towards you until he or she can hold their head up right because that's a safety concern with these products. In terms of warning labels for SITCs, this comes straight from the ASTM standard, which is referenced there. There is an example to address two hazards that have to be addressed in a warning label on your SITC, and they are a fall and a suffocation hazard. And for the fall hazard, you see there's an explanation or an instruction about infants being able to fall through a wide leg opening or out of a carrier. So you need to adjust the leg opening so that they fit the baby's leg snugly. Before each use, you need to make sure all fasteners, clips, any sort of retention system components are secure. You need to make sure you take special care when leaning or walking. Again, this is getting at changing the center of gravity for the caregiver that's wearing this item. You need to warn them never to bend at the waist, to bend at the knees, and to only use the carrier for children that are between a minimum and a maximum weight that you provide in pounds. To address the suffocation hazard, there needs to be a warning label stating that infants under four months can suffocate in this product if their face is pressed tightly against your body. So you need to make sure not to strap an infant too tight while wearing the product so that the infant isn't too tight against your body. You need to allow room for the infant to have head movement, and you need to keep the infant's face free from obstructions at all times. Now, this is just an example warning label that comes from the standard, but you want to make sure that you're warning. So, you know, you do have a little bit of ability to, you know, change the language here, but you still need to address the fall and suffocation hazards, and you need to make sure that you're addressing each of these things that the standard requires you to for those two hazards on your permanent warning label. It needs to be conspicuous, as well, and in sans-serif font, and it needs to be visible to the caregiver each time the occupant is placed in the carrier or when the caregiver places the product on his or her body. Now, let's compare and contrast that with slings. So, for marking and labeling on slings, it also needs to be permanently on the product and packaging, and this is coming from the ASTM requirement here, 29-07-15. We've got very similar requirements. Manufacturer, distributor, seller name must be permanently on the product and packaging, along with the place of business, city, state, mailing address, and zip code, and a telephone number. Again, that's from our durable's requirement in 1130.4. You need the model number, the stock number, or other identifying, or other symbol identifying the specific sling carrier. A code or a mark identifying the date, month, and year minimum of manufacture, very similar, again, to SITCs. And the minimum and maximum recommended child's weight for the carrier needs to be permanently on the product and the packaging per the ASTM standard. All right. For warning labels on slings, actually broken this into two slides. So, the concerns here are the same as they were with SITCs in terms of fall and suffocation. Let's address suffocation first. So, for the warning label for suffocation, you need the warning triangle, which is that triangle with the exclamation point in it, and the word warning along with these words. Failure to follow the manufacturer's instructions can result in death or serious injury. And you also need the warning label that states, only use this carrier with children weighing between. You need to include your minimum recommended weight for your product and maximum recommended weight in pounds for your product. For the suffocation hazard, I've included here the suffocation hazard warning straight from the ASTM standard, and it states the following. Babies younger than four months can suffocate in this product if face is pressed tightly against your body. Babies at greatest risk of suffocation include those born prematurely and those with respiratory problems. Check often to make sure baby's face is uncovered, clearly visible, and away from caregiver's body at all times. Make sure baby does not curl into a position with the chin resting on or near baby's chest. This position can interfere with breathing. Even when nothing is covering the nose or mouth. If you nurse your baby in carrier, always reposition after feeding so baby's face is not pressed against your body. And never use this carrier with babies smaller than eight pounds without seeking the advice of a healthcare professional. So that's the suffocation warning label on slings. Now to address the second hazard, the fall hazard, and again, this is the same concern with SITCs. I've included a pictogram that also came from the ASTM standard. This warning label needs to be in a contrasting color to your sling. So I do realize that my pictogram is white and my background is white. I did try to change the color of the pictogram, but it kind of skewed with the, messed with your ability to read the descriptions below the pictogram. So I elected to just leave it in white. However, if you're selling a white sling, make sure that your pictogram or your warning label is in a contrasting color. However, if it's a green sling, you can absolutely do it in white. So contrasting color, the warning label needs to be permanently on the product. This needs to be conspicuous and the text needs to be in sans serif font. And that's a requirement from the ASTM standard. And then a requirement from our agency that we actually added in addition to the warning label fall hazard proposed and are included in the ASTM standard is that warning labels must remain in contact with the fabric around the entire perimeter when in all use positions. And that is straight from our slings rag 1228. So you can see in the pictogram, it's got two pictures that show an upright and a reclined position and correctly wearing the sling with the baby in those two positions. On the right-hand side, we've got the two incorrect wearing positions in the pictogram that's showing the baby's face being covered or the baby being hunched with its chin against its chest. So in terms of warning labels, I wanted to show some examples where this has been done really well and it meets the requirement that the warning labels stay in full contact with the fabric around the entire perimeter when in all use positions and after undergoing use and abuse testing. So again, full disclaimer, these warning label examples are being used for illustration purposes. I'm not meaning to endorse any kind of product that they might be on. But on the left-hand side, you can see that there's really secure stitching all around the perimeter of this warning label. So after undergoing use and abuse testing or the physical and mechanical testing that we're going to talk about in just a second, this warning label stayed permanently affixed and that's exactly what we want under the new sling standard. The slings manufactured on or after January 30th of 2018. And on the right-hand side of the screen, you can actually see this was not a straight swath of fabric. This is a label that actually extends to both ends of the fabric and kind of curves in. But it was also permanently secured all around the perimeter so it was used as a very good example of how best to do this. So now that we've seen what to do, let's take a look at what we do and again these are samples that we've got from our testing lab. On the left-hand side you can see that this warning label actually frayed while the sling itself was undergoing use and abuse testing. So under the new standard effective January 30th of 2018 this would be a failure on the warning label because it's not permanently affixed all around the perimeter. On the right-hand side we've got a tag that's clearly just secured on the top which is not going to be passing because it doesn't go all around the perimeter. So because slings and SITCs themselves fall under the category of durable infant and toddler products with our agency another thing that you're going to want to make sure that you include is a product registration card. And this product registration card needs to be attached to the product and that's per our reg 1130. It needs to be a postage paid registration card. And the manufacturer receiving the product registration card needs to make sure to maintain records of the names, addresses, emails and other contact info on the consumers that send that card back to register their products. And again just highlighting this is exactly why you want to make sure that your manufacturer name, contact info, model number and name and data manufacturer are on your durable products because you're going to be asking consumers to put that information on a product registration card so that that can go into your database to maintain your records properly. So on the product registration card there is a little disclaimer that's on the bottom right of your screen and this is actually straight from our website which explains to consumers that this product registration info is for a safety alert or recall only and it's not us trying to sell, rent or share your personal information. But you as a manufacturer do have the ability on the product registration card to include in that last line how a consumer could go on to your website and you can provide the website there for them to register the product instead of mailing the card back snail mail. So we get a lot of questions about product registration cards and we've got a pretty handy frequently asked questions portion of our website that I think is a good point of reference. Your handout has that live hyperlink that's shown on your screen for the product registration card FAQs. Now testing requirements chemical testing requirements for SITCs and slings have combined because they mirror one another and the first thing is this is a children's product so we're concerned about lead. So lead content testing is at 15 USC 1228 or 1278A excuse me the limit is 100 ppm in accessible parts of the children's products and there are a list of materials that we know are not going to exceed that lead limit as long as they're untreated and unadulterated and in their unfinished state or unadulterated state and those are listed at 16 CFR 1500.91 I've done my best to highlight here in the four bullets materials that an SITC or a sling could be made of that appear in 1500.91 but it is not an exhaustive list 1500.91 is pretty extensive in all the things that it covers so I would encourage you guys if you've got a question about whether or not you need to lead test your SITC or sling or whether it might fall under 1500.91 list of materials to visit 1500.91 and again that hyperlink is in your handout on the right hand side of your screen. Another thing that we're concerned about is lead that might appear in paint or surface coatings and that testing requirement is from our reg 1303 the limit on lead and paint and surface coatings is 90 ppm and the most common way we see this in SITCs and slings or children's products at large is really things like screen printing if you are putting permanently on a product something that's not going to incorporate into the substrate it's going to lay on the surface of a fabric then that would be considered a surface coating and would be subject to the 90 ppm limit. So SITCs and slings are children's products so again we're going to be concerned potentially with small parts and a little background on small parts small parts are defined as things that fit entirely in a small part cylinder that's specified in our reg 1501 products that are intended for use by children under three cannot have small parts SITCs and slings are absolutely going to be used by children under three so a little bit of a distinction here functional parts of your SITCs and slings such as fasteners zippers and snaps are not going to be subject to the small part requirement but decorations that might be on a sling are a soft infant and toddler carrier would be considered a small part if they're not securely fastened onto the product and come off during use and abuse testing so we talked about the chemical testing requirements we talked about small parts which is something you want to be on the lookout for if you have decorations on your slings and SITCs now let's take a look at the physical and mechanical testing requirements so to start off this is a requirement for slings only which is that a sling needs to be washed and dried twice to determine whether shrinkage prevents the performance of the sling and this needs to be the first test that's conducted on a sling there is not a corresponding requirement for SITCs also for slings only there is testing that needs to be done on scissoring, shearing and pinching to make sure that doesn't happen while the sling is in use for both SITCs and slings hazardous sharp points or edges are a concern and the ASTM standards for both actually refer to rags 1500.48 and 49 on sharp points and sharp edges so if there is a wooden part of your SITC or your sling we usually see this in slings that have wooden rings that are ring slings you need to make sure that those wooden parts are smooth and that they're free of splinters and then for fastening mechanisms on the SITCs and if you have crotch and waste restraints in a sling this would also apply there the locking and latching mechanisms need to remain in their recommended use position before and after completion of all the use and abuse testing that we're about to go through and lastly SITCs and slings are subject to flammability testing under 16 CFR 1610 which is actually the wearing apparel flammability standard some more physical and mechanical testing requirements for SITCs and slings in terms of performance you want to make sure that the following things are met that there's structural integrity that remains on the SITC and the slings so we're looking for things like no seam separation while we're doing the testing there's no fabric tears and the fabric doesn't give way and that the attachment systems themselves don't break during the use and abuse testing we want to make sure that all the labelings and warnings that need to be on the product permanently actually remain permanently on the product during the testing and for warnings that are applied directly onto the surface of the product but you do have the ability to do that there is an adhesion test for those warnings that go that are directly printed onto the product and the adhesion test is actually using something sticky to see if that text is going to come off when that adhesion test is conducted and then lastly for leg openings this applies to SITCs only you need to make sure that the leg openings do not permit the passage of a test fixture which is a specific size based on the copyrighted ASTM standard that test fixture needs to be tested in all the recommended carrying positions and it shall not you need the test fixture not to fall through the leg openings during that testing alright so the physical and mechanical testing I thought it might be helpful if we actually showed some photos of this being done so that you got a good idea as you're designing your products what testing they're going to be subjected to so let me just orient you on your screen here so we've got two different test methods that are shown here I'm going to show four total on the left hand side of your screen we've got the static test and the test torso the static test is being shown on is the sling carrier testing torso and that's the size of that torso, the weight of that torso all of its dimensions are specified in the ASTM standard for slings there is a different test torso that's used for an SITC and let's focus on the static test first in the static test that is a sling being tested there and a weld cap of a specified weight again this is specified for the ASTM standard for slings because we're looking at a sling photo it would be a specified size and weight for an SITC and the SITC standard which is copyrighted so unfortunately we can't go through that today but a weld cap of a specified weight is going to be centered in the seat of the carrier to test its static strength and how it performs and you're going to be looking for the performance requirements to be met that we just went through so no seam separation then on the right hand side of your screen we've got a restraint system test that's being conducted here and this is actually being done on a sling and we know that because there is a cami doll laying on the table and a cami doll is part of the sling's restraint system test SITCs don't have a restraint system test they have a fastener strength and retention test which is a little bit of a different test procedure but for slings the restraint system test the way that it works is a pull force is applied to test for the restraint system disengagement and you can actually see on the cami doll in the picture that there is a connector around its foot and that there's a hook that's actually applying that pull force to the bottom of the cami doll to see how the system restraint or the restraint system performs when that pull force is applied so some more physical and mechanical testing that applies to SITCs and slings on the left-hand side of your screen we've got a dynamic test and again the test torso that's being shown there is a sling carrier test torso because that's a sling that's being tested and again the size of the test torso, its dimensions for both SITCs and slings are outlined in the voluntary standards for those two products so in the dynamic test a weight which you can see is attached to that chain is going to be dropped multiple times to the support area of the carrier to determine how much the system slips the carrier system slips as that weight is dropped and then on the right-hand side of your screen we've got the occupant retention test which applies to slings only and the test torso there again the slings test torso in the standard the sling test torso is required to wear a shirt however for contrast purposes because we've got a white test torso and a white sling he's not wearing a shirt so hopefully you're able to actually see the sling a little bit better than if he was wearing a white shirt too so I'm going to play the occupant retention video for you guys hopefully it shows up correctly on your screen and this test is meant to see whether or not a child is going to stay inside the sling as it's simulating walking alright so that was the physical and mechanical testing for SITCs and slings so after all that you're probably wondering hey I need to have some testing done how do I find a testing lab the good news is that we've got a lab search page I've got the hyperlink showing on your screen again in your handout that'll be an actual hyperlink that you can follow when you go to our lab search page you have the ability to narrow your search by region which is by country and by scope meaning the type of specific product testing that you need to have done in this case depending on whether you're making SITCs or slings you'll want to select one of the two regs that are listed there 1226 or 1228 and if you have problems with our lab search page admittedly we do receive some calls with people having problems conducting searching on it there's actually a video tutorial which is hyperlinked there in your handout and you always got the ability to contact us for help in locating a testing lab to help you test your consumer products so once you locate a testing lab you're probably wondering how frequently do I need to test well the answer is you've got to absolutely test initially because every consumer product that's got a mandatory standard associated with it needs to have testing done on it and SITCs and slings are no different so we've got a periodic testing rule that's an 1107.21 so you need to initially test and then for products in continuous production periodic testing is required at a minimum of once per year every two years with a production testing plan or every three years if you're using a testing lab that's accredited to the ISO standard that's listed on your screen the take away here on periodic testing is that the vast majority of manufacturers and importers are going to need to test their children's products slings and SITCs are included in children's products once per year when else might you need to have that testing conducted once you've had the initial testing conducted if you make a material change to your SITC or your sling you'll need to have testing done again and what is a material change we get a lot of questions on this so I've included the definition that's from our reg 1107.23 and it's defined as a change that the manufacturer makes to their products design to the manufacturing process or to the source of component parts for the product which a manufacturer exercising due care knows or should know could affect the product's ability to comply with the applicable children's products standards so we get some questions that are very specific on material change and I'm certainly no expert in what falls under material change but it does not but if you have questions specifically about material change please submit those to us and we can ask internally here the expert rely on the expertise of internal CPSC staff who are much smarter than myself so we mentioned a production testing plan just a second ago and I just want to go through the requirements there because this is another question that we get quite frequently on SITCs and slings and I've hyperlinked to our reg what is in a production testing plan which I would encourage you to take a look at if this is something that you're thinking you might want to implement in your company 1107.21 subsection C 2 the benefit of a production testing plan is that you get to test at least once every 2 years as long as you have no material changes which we just defined a production testing plan needs to be in writing it needs to describe the process management techniques that you're planning to use how frequently you're going to do those tests and what measurements you're going to take when you do the testing you also need to outline the number of testing samples that you plan to use when doing those frequent tests and you need to explain how those techniques and tests are going to provide a high degree of assurance to you and internally to us that you're going to be able to continue compliance with the standards that apply to SITCs or slings whichever you manufacture and the summary that I have here these bullet points do not include all the requirements I would encourage you highly if you're interested in potentially doing a production testing plan to visit that regulation and review the specific requirements there because there are a lot and I've only highlighted a few of them here you also have the ability to visit our frequently asked questions site on certification and third party testing which does answer some questions on production testing plans so once you've gotten all your testing done and your products have passed testing you need to prepare a children's product certificate because all children's products require that a CPC be in place this applies to manufacturers and importers you're basically certifying in a CPC that your products are complying with the applicable product safety rules there are two sample CPCs that you can use off of our website as a template to create your own those are available on the hyperlink cpsc.gov forward slash CPC that is shown on your screen and the two we've got on the site right now are for a children's toy and children's clothing but you're of course going to change the sections to you're going to customize them so that it covers your product so what is included in a CPC let's take a look at that because we do get a lot of questions about how to create one so on all children's product certificates there are seven sections and they're listed on your screen the one I want to highlight right now because it's what is going to be unique to SIT season slings not actually I mean number two is in every single CPC but I just want to touch on what would go in number two if you were creating a children's product certificate for a soft infant and toddler carrier or a sling carrier because this is where we get the most questions and number two you're asked to list the citations to each safety rule to which you're certifying compliance so in the case of these two carrier types you're going to list the following which we've already gone through today so this is kind of a nice refresher lead content lead and paint and surface coatings if that applies to your product if you have things like screen printing that don't incorporate into the substrate itself small parts regulation if you've got decorations that could fall under the small parts regulation or be a concern there flammability testing which is mandatory for all soft infant and toddler carriers or sling carriers and then finally your physical and mechanical testing which we just went through comes from our regs 1226 and 1228 and the corresponding ASTM standards which are listed there for SIT season slings so obviously if you're creating a CPC for slings you're only going to list 16 CFR part 1228 and ASTM F2907-15 you're not going to list the SITC sections or vice versa if you're making a soft infant and toddler carrier in number two of your children's product certificate you will only list 16 CFR part 1226 and ASTM F2236-14 so CPCs need to be available in the following three situations that are the most key number one is they need to accompany each shipment of a product covered by the certificate and they need to be furnished by distributor or retailer of the product that you might be working with there is no requirement that you need to provide it to the ultimate consumer however you absolutely have the ability to do that that is just not a requirement that's mandatory from us a copy of the certificate needs to be made available as well to our agency or customs and border protection upon our request and in terms of electronic certificates because you know people are trying to move to a paperless way of communicating our commission by rule has confirmed that electronic certificates are acceptable ways of complying with the children's product certificate requirement however there is a caveat which is that if you are going to rely on electronic certificates you need to make sure that they are created no later than the time of shipment if they are being imported into the US or first distribution within the United States if you are a domestic manufacturer meaning you can't go after the fact and create a certificate and try to back date it to cover something that is already in commerce all right let's touch on two recall examples here the first one is a soft infant and toddler carrier that had a problem with internal stitching on the carrier itself being missing meaning that when a child was seated in the carrier they could actually fall out and fall through the bottom so this recall is actually dated September 21st of 2016 there were about 900 units sold here in the US about 600 were sold in Canada and the remedy here was refund or replace the carrier and we see recalls like this somewhat frequently and the reason that we highlight them here is just to try to help everybody who is attending today learn from recalls of the past so we can all make safer products going forward the second recall example I've got is also a soft infant and toddler carrier and in this case the recall was again a fall hazard because the side strap on the soft infant and toddler carrier could loosen unexpectedly also meaning that the child could fall out of the carrier so this recall is dated October the 13th of 2016 there were about 130 of these SITC sold in the US and about an additional 1000 in Canada that were impacted by this recall the remedy here was a repair side strap to solve the problem so before we get to questions I just want to highlight a few CPSC business resources that I want to make you aware of the first thing is you've got my email address on your screen please feel free to email me questions that you've got I tell everybody you can email me questions I might not always know the answer but I can try to find out the answer for you we've got a lot of smart people here at this agency much smarter than me who are great about helping trying to provide answers to the public and especially to manufacturers that are attending today so you can email me you can also call the phone number that's on your screen the 301-504-7945 number is a business line that actually rings at my desk and my colleague Will's desk so as long as we're seated at our desk and we're not on another line or in a meeting we answer that phone and try to answer your questions when you call if you are on Twitter and you're interested in following us on Twitter you can do so we have a small business specific Twitter account that's at CPSC Small Biz and we put things on it such as today's webinar or things that are coming up in the commission in terms of public hearings that you might be interested in attending or watching on your computer or other trainings that are going on within the agency that are open to the public that you might be interested in on the left hand side of the screen I've got that lab search page to help you find a testing lab for your SIT season slings and I've got a desktop reference guide in the event that you make a product other than SIT season slings if you want to know what the requirements are there the desktop guide does a nice job of breaking that down by consumer product and then on the right hand side of the screen I've got the regulatory robot which is an interactive bot that asks you a series of questions and it will ask questions about soft infant and toddler carriers and sling carriers and produce for you a report that highlights some of the requirements that might be applicable to your product based on the answers that you give and that regulatory robot is available via hyperlink that you can just click in your handout and lastly I also want to touch on one last thing or two last things one is that for those of you that frequent our website cpsc.gov under the business education pages you can access from the menu screen or the menu bar at the top right of the page we now have a sling carrier guidance page which actually went up today in conjunction with this webinar so all of the testing requirements, labeling requirements instructional literature requirements and product registration card requirements that we went through today will be listed on that business education page so if you forget something from today you can't find your handouts and you want to just have an easy source of reference that sling carrier's business education page is a great one there is already a corresponding one for soft infant and toddler carriers so I would suggest that you visit that as well and then lastly before I get to questions that you guys have submitted throughout the webinar I also wanted to mention if you want to stay up to date on webinars that we might have upcoming please sign up for our newsletter I send that out monthly sometimes I will send out an update mid month then it comes up and it's somewhat time sensitive and I want to make sure it gets on your radar you can sign up for our monthly newsletter at cpsc.gov forward slash email and from that page you want to make sure that you select small business ombudsman updates well with all that said we're actually out of time and I want to make sure we end on time thank you to everybody who attended the webinar today after I close it out you're going to get a short feedback survey that pops up I would encourage you to fill that out if you're so inclined, we really appreciate it we're trying as an agency to do a better job of getting feedback from people that attend events like this and it helps us know what you like best so that next month's webinar we can make sure we incorporate that so thank you everybody and have a good rest of your day