ASTM STANDARD FOR TOYS Here are some highlights of F963-86, "Consumer Safety Specification on Toy Safety" ,which might be of interest to amateur woodworkers and hobbyists. I've paraphrased a lot to reduce the length, and left out parts that didn't seem applicable to woodworkers; therefore, do not use this information in place of the standard itself. Section 3 contains definitions. Section 4 describes specific hazards for various kinds and parts of toys. Section 8 has a battery of test methods. The Annexes have a bunch of useful comments regarding age grading. 3.5 hazardous edge: an accessible edge that presents an unreasonable risk of injury during normal use and reasonably foreseeable abuse of a toy. Metal glass edges on toys intended for children under the age of eight years are defined as potentially hazardous if they fail the sharp edge test described in 16 CFR 1500.49. Edges other than metal and glass are defined as potentially hazardous if they are sharp to the touch under conditions of casual handling. 3.16 hazardous point: an accessible point that presents an unreasonable risk of injury during normal use or reasonably foreseeable abuse. Points on toys intended for children under the age of 8 years are potentially hazardous if they fail the sharp point test described in 16 CFR 1500.48. 3.18 hazardous projection: a projection that, because of its material or configuration, or both, may present a puncture hazard if a child should fall onto it. 4.1 Material Quality - Toys shall be constructed of new or reprocessed material that has been so refined that the level of contamination from hazardous substances does not exceed that found in new material. 4.2 Flammability -Materials other than textiles used in toys shall not be flammable as defined under 16 CFR 1500.3 (c) (6) (iv) under the Federal Hazardous Substances Act. I suppose wood is probably out, but we'll just have to ignore this one! 4.3.5 Paint and Similar Surface-Coating Materials - should comply with the lead content provisions of 16 CFR 1303. Subpoints indicate allowable percentages of things like lead, arsenic, cadmium, mercury, selenium, barium, chromium, that sort of thing. It would be nice to have a list of manufacturers of "safe" finishing materials. Net people have suggested Cherry Hill, Watco, and the water-based finishes from Carver-Tripp. Behlen makes a Salad Bowl Finish that's supposed to be non-toxic when dry. 4.6 Small Objects - intended to minimize hazards from ingestion or inhalation of small objects, or pieces that break off or are removed from toys. Do tests both before and after abuse testing in accordance with section 8. 4.6.1 16 CFR 1501 states, in part, that no toy or fragment of a toy shall be small enough to fit entirely within a given test cylinder. The figure shows a cylindrical hole 1.25" in diameter and 2.25" deep, but it's got a slanted bottom so it's only 1" deep on the shallow side. Paper, fuzz, string and the like are excluded from the requirement. The test is intended for children under 3 years, but probably wouldn't be a bad guideline for any age. 4.7.5 Exposed bolts or threaded rods - If the ends are accessible, the thread shall be free of exposed sharp edges and burrs. If covered by finish caps, test with the compression, tension, and torque tests (8.8- 10). 4.8 Accessible points - Toys shall not have accessible potentially hazardous sharp points that may occur because of the configuration of the toy, assembly devices such as wires, pins, nails, and staples that are poorly fastened; poorly sheared sheet metal; burrs on screws, and splintered wood. A "sharp point" is defined in 16 CFR 1500.48, and a design for an elaborate tester is given -- a spring-loaded head and a battery-driven lamp. Essentially, a point which goes through a .040"x.045" opening farther than .005" fails the test. 4.8.3 Wood - The accessible surfaces and edges of wood shall be free if splinters. (By the way, "accessible edge" was given a technical definition, and a hinged probe with specified dimensions was shown. It's too complicated to reproduce, but simulates a 2-joint finger about 2 inches long and 1/4" thick -- the dimensions vary for different ages). 4.9 Projections - long discourse stating that long thin things that might stick up if the toy is laying on the floor should be covered by a cap or something to prevent puncture wounds if the kid should fall on it. 4.10 Nails and fasteners should not protrude (they shouldn't anyway!). 4.13 This section covers strings and elastics, including monofilaments, plastic tapes, chains, and anything similar. 4.13.1 Crib and Playpen Toys - any string should be less than 12 inches long, total. 4.13.2 Pull Toys - String longer than 12 inches intended for children under 3 years should not have beads or attachments that could tangle to form a loop. (Strangulation danger, I suppose this is). 4.13.3 Self-retracting Pull Strings should not retract with a 2 pound weight hung on the end. So I guess it should require no more than 2 pounds to keep the string pulled out. 4.13.4 Accessible unaffixed elastics in toys intended for children under 36 months of age shall not extend to more than 12 inches under a load of 5 pounds. 4.14 Wheels, Tires, and Axles - These requirements are intended to eliminate the possibility of ingestion hazards that might be caused by small wheels or tires that separate during normal use or reasonable foreseeable abuse, and laceration or puncture hazards from projecting axles, either on the toy or on wheel assemblies that may be removed from the toy during abuse. The requirements shall apply to wheels on toys intended for children under 8, except for ingestion hazards from small wheels and axles, which apply to toys intended for children under 3. After being subjected to the use and abuse tests of 8.5-8.11, wheels, tires, or axles shall not present a laceration or ingestion hazard as defined in 3.16, 3.18, and 4.6.1, respectively. 4.15 Folding Mechanisms and Hinges - Requirements intended to eliminate possible crushing, laceration, or pinching hazards. Examples are sudden collapse or motion that produces a scissor action, or a gap in a hinge that could admit a finger while closing. 4.15.1 Folding Mechanisms - toy furniture and such with a folding mechanism or brace that's intended to support the child's weight should have a safety stop or locking device, and /or provide adequate clearance to protect fingers, hands, and toes. 4.15.2, Hinge-Line Clearance, and 4.16.1, Clearances for Moveable Segments, say that any gaps between moving parts (like lids or wheels or fenders) should be either less than 3/16" or greater than 1/2" at ALL positions. 4.16.2 is intended to avoid finger entrapment which could cut off blood circulation. If a hole is accessible and can admit a 1/4" rod to a depth of 3/8" or more, it should also admit a 1/2" rod. 4.16.3 Chains and Belts -- intended to protect against crushing, pinching, and finger entrapment between links of supporting chains or between chains, sprockets, pulleys, and belts. 4.16.3.1 Chain should be shielded if it's accessible and the links have openings more than 0.19" wide. 4.16.4 Inaccessibility of Mechanisms - clockwork and other drive mechanisms should be shielded or inaccessible. Their test is a 1/4" rod 3" long. Also, where mechanisms are located near openings 1/4" to 1" wide, there shall be no pinch or laceration hazard in any direction within 1.5" of the inside periphery of the opening. (For the kid who puts a finger in, bends it, and probes around, as they are wont to do). 4.16.5 Winding Keys - For keys on toys for children under 3 years, where the toy rotates as the mechanism unwinds. If the flukes of the key are more than 1/4" from the body of the toy, they should be at least 1/2" away. No opening in the flukes should admit a 0.19" rod. 4.16.6 Coil Springs - for prevention of pinching or crushing during compression or extension, on riding toys. Spring gaps should be less than 0.12", or more than 1/4", even when a 70 pound weight is bouncing on it. 4.17 Stability and Over-Load requirements: This section mostly covers the stability of riding toys. It's long, so I'll summarize a lot. 4.17.2.1 Sideways Stability - Ignore sideways stability where the seat is under a given height, as long as the feet are free to be used for stabilization. The height varies with age: 9 inches for a 1-year-old, and increasing essentially 1 inch per year of age. For seats above the limit, use the tip test in 8.16. 4.17.3 Fore and Aft Stability - Use tip test in 8.16, but use a 15 degree incline and apply the load to the least favorable part of the seat, with handlebars (if any) in various positions from straight ahead to 45 degrees left and right. 4.17.4 Stationary Floor Toys - If it's higher than 30 inches and heavier than 10 pounds, make sure it doesn't tip when placed on a 10 degree incline even with all movable portions extended and pointing downslope. 4.17.5 Overload Requirements for Ride-On Toys and Seats - Seats should bear 3 times a child's weight, where the weights are (age- pounds): 1-28,2-29,3-42,4-43,5-50,6-59,7-69,8-81,9-89,10-105,11- 121,12-120,13-140,14-153. That's right, a rocking horse for a 5- year-old should support 150 pounds without bending, breaking, or pinching. 4.18 Confined Spaces - to eliminate possible entrapment in enclosures such as toy refrigerators, or suffocation in things like space helmets. 4.18.1 Ventilation - Toys with doors or lids with volumes over 1.1 cubic feet, where internal dimensions are 6 inches or more, should have an unobstructed ventilation area of greater than 2 square inches over 2 or more separate openings situated at least 6 inches apart when the toy is placed on the floor in any position and adjacent to two vertical walls. (Permanent bars or partitions could be used to separate the space inside so that a child won't fit inside, if that's not the intent). 4.18.2 Closures to enclosures described in 4.18.1 shall not be fitted with automatic locking devices. Closures should open with a force of 10 pounds or less when pushed in an outward direction anywhere within 1 inch from the center of the closure. 4.20 Projectile Toys - covers things like slingshots and darts. [Take these with a grain of salt, such toys are probably "dangerous" by their very nature.] 4.20.1.1 No projectiles should have sharp edges or points, nor should they fit within the cylinder described in 4.6.1. 4.20.1.2 No projectile shall have a tip radius less than 0.08 inches. [Even this seems to small to me! -KE] 4.20.1.3 Any projectile with a kinetic energy that exceeds 0.08 J (as determined in 8.15.1) should have an impact surface made of resilient material. 4.20.1.4 Protective tips should not detach when subjected to the torque and tension tests 8.8 and 8.9, and shall not produce or reveal hazardous points or edges when fired into a solid object according to the test procedures in 8.15.4. 4.20.2 Discharge Mechanisms - your gun shouldn't work with things like pencils and rocks. 4.21 Rattles -- covered separately in 16 CFR 1510. A test fixture has a rounded rectangular opening 1.378" high and 1.968" wide, and 1.181" deep -- apparently no part of the rattle should be able to go through it (as when a baby puts it in his mouth). An additional test has a circular hole of the same depth, with a diameter of 1.68". 4.22 Pacifiers - covered in 16 CFR 1511. There's a test fixture shown with a strange-looking opening that I won't try to describe for fear of misunderstandings, and a note about limiting levels of nitrosamines to 60 parts per billion. I doubt if anyone's building wooden pacifiers, anyway! 4.24 Teethers - conforms to the same tests as rattles. 4.25 Crib Gyms, Crib Exercisers, etc. - I think these are hanging toys intended for kids to play with while lying in a crib. The warning is to do away with the toy as soon as the baby begins to push up on hands and knees, approximately 5 months of age, so that no entanglement will occur. Also, in 6.3.1 they warn not to hang the toy close to the baby -- it's to be within reach of the hands, but clearly out of reach of face and mouth. 4.26 Toy Chests - minimize the possibility of entrapment, strangulation, crushing, pinching, or suffocation. 4.26.1.1 Vertically opening hinged lids should have supports such that if the lid is dropped while being opened, it will not fall more than half an inch. See test in 8.14.1. This should be true even after 7000 opening and closing cycles, without requiring adjustment of the lid. (I wish they'd give an example of a mechanism that would comply with their requirements!) They also remind you of the guidelines in 4.15.2 and 4.18. 8. Test Methods 8.1 All toys should go through 8.5-8.10. The order doesn't matter, except where specified. Many parts of section 4 said to do the abuse test before doing the others, for example; also, do 8.4 before running any tests. 8.4 Preconditioning - Cycle the temperature to 0 degrees Fahrenheit (4 hours), room temperature (4 hours), 130 degrees (4 hours), and back to room temperature for 4 hours; repeat this cycle. 8.5 Normal Use - Simulate normal play mode, with the intention of uncovering hazards (the fact that a part breaks is only relevant here if it produces a hazard -- the test is not for reliability or quality). Use all the parts of the toy, and do it in the intended environment (say, soapy water for a bathtub toy or in sand for a sandbox toy). 8.5.1 Washable toys - run the toy through 6 machine wash and dry cycles. 8.6.1 Abuse Testing - The tests in 8.7-8.13 are the "reasonably foreseeable abuse" tests. Severity differs with the age of the child. If the toy is built to be assembled by a child, test each piece separately as well as the assembled toy. 8.7.1 Drop Test - Drop in random orientation. Evaluate after each drop. Drop onto a 1/8" thickness of tile over concrete at least 2.5" thick. Impact area should be 3 square feet or more. The height and number of drops is as follows: up to 18 months old, 10 times over 4.5 feet; other children, 4 times over 3 feet. (Why is this, I wonder? I would have thought the older kid would drop it more, from and farther). 8.7.3 Tumble Test for Wheeled Toys - Tumble down a flight of 6 steps with risers at least 7 inches high. Do it twice for each orientation: forward, backward, and sideways both ways. Test is complete even if the toy does not reach the bottom. 8.8 Torque Tests for Removal of Components - for any parts which can be grasped with the thumb and forefinger, or the teeth. Put a clamp on the component and attach to a torque gauge, and twist in both directions for 15 seconds as follows: up to 18 months, 2 inch-lbf; up to 3 years, 3 inch-lbf; up to 8 years, 4 inch-lbf. 8.9 Tension Test for Removal of Components - Any projection of a toy that a child can grasp with at least the thumb and forefinger or the teeth shall be subjected to this test. Clamp each test component and apply tensile for for 15 seconds, once parallel to the major axis of the component and once perpendicular. The forces are as follows: up to 18 months, 10 pounds; older children, 15 pounds. 8.10 Compression Test - For any surface of the toy that was not accessible to flat surface contact during the impact test in 8.7.1. Press a rigid metal disk 1.125" in diameter onto the area for 15 seconds with the following force: up to 18 months, 20 pounds; up to 3 years, 25 pounds; up to 8 years, 30 pounds. 8.11 Removal of Wheels and Axles- Clamp the toy, and use a hook to hang 10 pounds on the wheel or axle for 15 seconds. For children up to 3 years of age, use 15 pounds. Do the test with the axle both vertical and horizontal. If a wheel-and-axle assembly pulls off the toy, do a further test: turn the axle to vertical, set one wheel on a plate with the axle over a hole, and apply 20 pounds to the upper wheel to see if the axle can be made into a "projection hazard" by sliding the wheels down the axle. 8.12 Flexure Test - for flexible toys. Secure in a vise with rounded jaws and bend 60 degrees from the vertical each way. Repeat that cycle 30 times, once every 2 seconds with a 1-minute rest every 10 cycles. 8.13 Test for Mouth-Actuated Toys (whistles, flutes, what have you) - Use a piston pump capable of discharging and taking in more than 18 cubic inches of air in less than 3 seconds. Subject the toy to 10 alternating blowing and sucking cycles. If the outlet is accessible to the child, do the same thing to the outlet. 8.14 Lid Support Mechanisms - Lift the lid to any position in its arc of travel to a distance greater than 2 inches but not over 60 degrees from the fully closed position. Release the lid and observe any dropping motion. Subject the lid to 7000 full opening and closing cycles, within the space of 72 hours. Repeat the support mechanism test. 8.14.2 Closures/Lids - test for conformance to 4.18.2 by pushing with a gradually increasing force perpendicular to the plane of the lid at a point within 1 inch from its geometric center. The force required to cause the lid to begin to open should be less than 10 pounds. 8.15 Projectiles - Calculate kinetic energy as mass in kilograms times velocity in meters per second. Measure the velocity across a distance of not more than 1 foot of flight; also, use the average of 5 measurements. For impact tests, fire the projectile from their discharge mechanism perpendicularly into a concrete wall 1 foot away. 8.16 Test for Stability of Ride-On Toys - Place the toy on a 10 degree slope (15 degrees for some toys, as noted in the relevant part of section 4). Turn steering mechanism, if any, to a position where the toy is most likely to tip. Chock wheels to restrict rolling. Apply a static load in the seat as follows (age-weight): 1-28, 2-29, 3-42, 4-43, 5-50, 6-59, 7-69, 8-81, 9-89, 10-105, 11-121, 12-120, 13-140, 14- 153. Annexes -- these are useful comments so I'll type them out. Good age grading practices are important to assure a toy is appropriate and safe at particular stages of physical and mental development. Some criteria must be considered. The physical ability of a child to manipulate and play with the specific features of a toy necessitates an understanding of the physical coordination, motor capabilities, size, and strength generally available at a given age. The mental ability of a child to understand how to use a toy is important to provide a concept which will challenge and stimulate, yet not frustrate. Accomplishment should be neither too easy nor too difficult to be satisfying to the child. Understanding developmental levels and identifying play materials and play environments to enhance each developmental stage is important in assigning appropriate age grades. Interests and preferences change rapidly; a toy must be appealing to its user. The toy must be safe for the intended user. Age grades are indicators of "average" development which does not necessarily reflect suitability for the exceptional child. A primary consideration should be potential choking and aspiration hazards associated with small parts. Toys appropriate for children under three years: squeeze toys, teethers, crib exercisers, crib gyms, mobiles, stroller, playpen or baby carriage, pull and push toys, pounding toys, blocks and stacking sets, bathtub toys, sand toys, rocking horses, spring and stick horses and other figures, chime and musical balls and carousels, jacks-in- the-box, stuffed animals; and those toys, games, puzzles, riding toys, dolls, cars, and trucks that are intended for use by children under 3 years. Specific characteristics of the above toys: A1.4.4.2 Infant toys, intended to be used in a crib or playpen, to be held easily by small hands, shaken, grasped, rattled, or cuddled. A1.4.4.3 Toy Vehicles - cars, trucks, boats, trains of simple chunky shape, decorated in primary colors without extensive descriptive detail or representation of a particular make or model of vehicle. A1.4.4.4 Action Toys - Simple action toys for identification of sounds or pictures and surprise action toys. A1.4.4.5 Early Learning - Toys and books for learning the basics, letters, numbers shapes, and simple physical motions such as turning wheels or knobs, pulling and letting go, sorting by size, etc. A1.4.4.6 Blocks and stacking toys that do not require finger dexterity or fitting together of small intricate pieces. A1.4.4.7 Soft Balls or other shapes for squeezing, shaking, rolling, or tossing. Toys that are inappropriate for very young children are: those that require intricate finger movements or controlled adjustments, fitting intricate pieces together; games or toys that require or incorporate elements of reading ability; toys that simulate adult figures or characters and their associated accessories; collecting sets; projectile or launched toys; makeup sets; toys with long cords or straps. Some toys require instructions and caution statements and should only be used by children who can read those for themselves, generally age 8 or greater. Such products include: science sets with glass components and or complex instructions; complex model and craft sets; electrically operated toys incorporating heating elements; chemistry sets or model vehicles (like rockets or gas-powered cars) which use hazardous chemicals. Many of these articles would require adult supervision as well. ------------------------------------------------------------------------ ------------------------------------------------------------------------ RELEVANT STANDARDS ORGANIZATIONS and spec numbers American Society for Testing and Materials (ASTM) 1916 Race St. Philadelphia, PA 19103 Annual Book of ASTM Standards, Section 15, volume 7, "End Use Products", contains: F404 - Consumer Safety Specification for High Chairs F406 - Consumer Safety Specification for Play Yards F833 - Consumer Safety Performance Specification for Carriages and Strollers F834 - Consumer Safety Specification for Toy Chests F963 - Consumer Safety Specification on Toy Safety F966 - Consumer Safety Specification for Baby Crib Corner Post Extensions F1148 - Consumer Safety Performance Specification for Home Playground Equipment F1169 - Specification for Full Size Baby Crib (a few of many in this volume; I'll leave out the others, like Test Method for Access Depth Under Furniture of Vacuum Cleaners and Specification for Pole Vault Landing Pits) American National Standards Institute (ANSI) 1430 Broadway New York, NY 10018 Z 315.1 - Safety Requirements for Tricycles Z 66.1 - Specification for Paints and Coatings Accessible to Children to Minimize Dry Film Toxicity Consumer Product Safety Commission Washington, DC 20207 16 CFR 1500 - Hazardous Substances Act Regulations, including sections: 1500.18 Banned toys and other banned articles intended for use by children 1500.48 Determining a "sharp" metal or glass edge in toys 1500.50-53 Simulating use and abuse of toys for use by children 16 CFR 1501 - Small parts regulations 16 CFR 1510 - Requirements for Rattles 16 CFR 1511 - Requirements for Pacifiers