Hello Ed, I have done a product to the Toy Directive and I have experience with the EN 71 series standards. The items you mention would fall under EN 71-1 which covers the physical properties of toys. In particular, the elastic cords would need to comply with section 5.4 “Cords, chains and electrical cables in toys”. This section is intended to prevent children from being strangled by cords. The standard does not assess the risk of injury due to the quick release of energy stored in an elastic band. For springs, it covers the risk of injury from part of the body getting caught between the coils of springs, but it doesn’t specifically regulate the strength of springs.
There are classes of toys, such as yoyo balls, that include elastic cords and are specifically covered in EN 71-1. The requirements for a yoyo ball elastic cord might be applied to the elastic cords for other toys and the standard does give fairly specific requirements. However, the consideration is still strangulation and not the sudden release of stored energy. There are different considerations if you produce a product intended to use stored energy to launch a projectile. EN 71-1 section 4.17 covers projectile type toys and there are tests for stored energy for products such as a toy bow and arrow. However, these requirements only apply to products intended for this purpose. There are a few assumptions commonly made in assessments of this type of product. First, a young child would not likely have the strength and manual dexterity to cause injury if they figured out how to use such a product as a slingshot. Second, an older child that could use such a product as a slingshot will likely figure out how to cause injury or property damage by using just about any type of toy or product as a weapon. There is little the standards can do to protect from the inventiveness or intent of such a child. You just have to wait for them to grow up and become either an engineer. Ted Eckert Compliance Engineer Microsoft Corporation ted.eck...@microsoft.com<mailto:ted.eck...@microsoft.com> The opinions expressed are my own and do not necessarily reflect those of my employer. From: dougp01 [mailto:doug...@gmail.com] Sent: Tuesday, May 5, 2015 12:33 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Toy Directive Ed, I have not personally been through a Toy Directive review but I have been involved with consumer products which have hazards and may exhibit "child appealing" attributes. In short, these product were listed on a red list which means they cannot be approved, or possibly they can be approved when used only under adult supervision. A classic example was a steam vaporizer with a shape resembling a cute animal. Choking hazards aside for the moment, in the case of this toy being fashioned into a sling shot, I have to wonder if there would be enough projectile energy to cause injury. Best, - doug Douglas Powell http://www.linkedin.com/in/dougp01 Original Message From: Ed Price Sent: Tuesday, May 5, 2015 11:58 AM To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG> Reply To: Ed Price Subject: [PSES] Toy Directive I was at a symposium recently where hundreds of (strictly non-electrical or otherwise powered) puzzles and games were being rated (for aesthetics such as age level, fun and intellectual challenge). However, nobody at this event gave any consideration to the familiar regulatory compliance issues such as choke hazard, biological safety, stored energy or “unintentional uses.” I began thinking about this when I examined a very simple toy consisting of 16 equal ¼” diameter, 4” long polystyrene tubes strung in series on a thin bungee cord. The string of tubes can be torqued into forming many (over 200 claimed) stable “wire frame” three dimensional objects. I was sitting there, twisting this thing into cubes and polyhedrons, when I realized that it could also form a very credible slingshot! I then noticed a very prominent “CE” on the box. I wonder if anyone in our group has ever done a product compliance with the Toy Directive. Maybe my background in defense is showing, but it seems to me that only a great toy can stimulate, amuse, educate and also be converted to a weapon. Ed Price WB6WSN Chula Vista, CA USA - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <emc-p...@ieee.org<mailto:emc-p...@ieee.org>> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe)<http://www.ieee-pses.org/list.html> List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <sdoug...@ieee.org<mailto:sdoug...@ieee.org>> Mike Cantwell <mcantw...@ieee.org<mailto:mcantw...@ieee.org>> For policy questions, send mail to: Jim Bacher <j.bac...@ieee.org<mailto:j.bac...@ieee.org>> David Heald <dhe...@gmail.com<mailto:dhe...@gmail.com>> - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. 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To post a message to the list, send your e-mail to <emc-p...@ieee.org> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <sdoug...@ieee.org> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org> David Heald: <dhe...@gmail.com>
