1. Toy Safety Certification Program SM
As of October 7, 2008

2. Genesis of the TSCP What is Needed
Restore the reputation of and consumer confidence in the toy industry
Address problems earlier in the production process
Reduce redundancies
New U.S. Federal Law
Every manufacturer shall have their toy products tested by a qualified lab and certify that the product meets safety standards
TIA Board Decisions
Supported U.S. federal law for mandatory testing
Implement private sector certification system (TSCP)

3. Purpose of the TSCP Objective
To develop a sustainable system to enhance both the reality and the public’s confidence that toys sold in the U.S. market are safe
Provide Definition
How many units must be tested?
How is the testing to be done?
What is the criteria for testing frequency?
Who can certify that products meet requirements?

4. Development of the TSCP
August 2007 – TIA engaged ANSI to coordinate a public- private partnership to develop conformity assessment guidance
February 2008 – Resulting document was published for public comment
March 2008 – Written comments reconciled at two-day meeting attended by key representatives from the toy safety community  
April 2008 – Meetings in Hong Kong, Beijing and Brussels
May 2008 – Resulting program is more effective, realistic and credible – but still a work in progress
June 2008 – Presented at ICTI Annual Meeting
Summer/Fall 2008 – Refining program and identifying opportunities to minimize redundancies

5. Program Requirements Applicants are responsible for:
Hazard and risk assessment for toy product design
Factory process control audits by an independent audit body
Production sample testing by an accredited laboratory to validate that the factory is producing toys that meet U.S. safety standards
Will be verified by ANSI-accredited Certification Bodies
Upon successful completion of applicable requirements the toy is certified and the product or packaging may bear a toy safety mark

7. CPSC Implementation Timetable

8. TSCP Part 1
First focus on testing to meet the more immediate need for compliance with federal legislation
Labs meeting CPSC 3rd Party Conformity Assessment Body Accreditation Requirements would offer testing compatible with TSCP
All applicable F963 and CFR Testing
Follow up testing required in TSCP Part 2 or if CPSC requires higher frequency sooner
No TSCP mark issued
Capacity building and testing before expansion to all program elements
Benefits include quicker TSCP certification, priority for factory audits, test results already in the system, easy access for retailers to confirm compliance

9. TSCP Part 2
Added Prevention Program: Design Analysis and Factory Process Control Audit added to Testing
Better ensures toy safety
Full certification for product complying with TSCP requirements
Use of TSCP mark
Full TSCP Program (No longer Parts 1 and 2)

11. Hazard Analysis/Risk Assessment
Design issues were the cause of many toy safety recalls
Must be performed by qualified staff or third party
Under the direction of a company official
Must use systematic analysis tools such as those contained in
ISO/IEC Guide 50 and/or 51
Handbook for Manufacturing Safer Consumer Products (US CPSC, July 2006)‏
Risk Assessment Guidelines for Non-Food Consumer Products (European Commission)‏
Company official must provide attestation to Certification Body

12. Process Control Audit
Poor process controls caused many toy safety recalls
Conducted by audit firm accredited to ISO by a member of the International Accreditation Forum (IAF)‏
Auditor(s) having specific training in TSCP audit
Each audit question will be rated as Acceptable, Needs Improvement, or Unacceptable
Corrective Action Plan (CAP) must be submitted for all audit findings
Follow-up visits will be conducted based on CAP and severity of the findings
Unannounced follow-up audits will be conducted on an approximately annual basis

13. Process Control Audit Content
Quality Management System
Resource Management
Incoming Material Control
Process and Production Control
Final Product Control and Traceability

14. Process Control Audit Evaluation
Findings of Critical, Major or Minor Issues
Factory ratings based on amount and severity of issues
Tier 1 – Substantial compliance with all requirements
Tier 2 – Basic process control with improvements needed
Tier 3 – Factory lacks basic process control system

15. Testing Frequency FREQUENCY A – TIER 1 FACTORIES
Complete testing annually or every 1 million units
Intermediate test focused on heavy metals
FREQUENCY B – TIER 2 FACTORIES
Minimum semiannually or every 500,000 units
ISO 9001 factories can begin at Tier 2 pending an audit
FREQUENCY C – TIER 3 FACTORIES
Minimum quarterly or every 150,000 units
Can be less when production is less than 1,000 units a year
CPSC testing frequencies have not yet been specified
TSCP frequencies will be modified to be consistent with any future CPSC requirements

17. Role of Toy Companies
TSCP will build upon, not replace, manufacturer accountability
Are responsible for meeting federal and CPSC requirements
Maintain own “culture of safety”
Design assessments, factory evaluations and toy testing should already be a part of doing business

19. Oversight Oversight Council / Board of Governors
Advise TIA’s Board regarding development, implementation, penetration and effectiveness of program
Industry and public interest representatives
Technical Committee
Will advise Oversight Council and TIA Board on technical aspects of the program

20. Outreach U.S. Consumer Product Safety Commission
U.S. Legislators and State Government Officials
Chinese and HK Officials and Industry (implementation)
European Union Officials and Industry (compatibility)
Companies Manufacturing in Other Locations
Small Companies
Retailers
Consumer Groups

21. Value of TSCP
Will improve toy safety, reduce criticisms and help increase consumer confidence
Provides a mechanism for instant and centralized access to test reports, factory status, certified product
Offers a one-stop shop for multiple retailers
Expected CPSC recognition that TSCP certification demonstrates due diligence (i.e. fireworks program)
Exceeding federal requirements through TSCP offers toy companies a way to differentiate themselves
TSCP product and factories will be considered less risky and therefore subject to less retailer, government oversight
Costs and redundancies will be reduced over time
Other toy safety certification programs will not be able to offer what this industry initiative can

22. Next Steps TSCP still in development
Building out information systems platform
Refine TSCP requirements based on:
Evolving CPSC requirements
Continued testing of requirements
Further discussion with international partners
Opportunities to minimize redundancies
Begin TSCP Part 1
December 2008 follow-up meetings in China

23. Toy Safety Certification Program SM
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