CEN TR 15371-2-2017 Safety of toys - Interpretations - Part 2 Replies to requests for interpretation of the chemical standards in the EN 71- series.pdf

1、Safety of toys InterpretationsPart 2: Replies to requests for interpretation of the chemical standards in the EN 71-seriesPD CEN/TR 15371-2:2017BSI Standards PublicationWB11885_BSI_StandardCovs_2013_AW.indd 1 15/05/2013 15:06TECHNICAL REPORT RAPPORT TECHNIQUE TECHNISCHER BERICHT CEN/TR 15371-2 May 2

2、017 ICS 97.200.50 Supersedes CEN/TR 15371-2:2015English Version Safety of toys - Interpretations - Part 2: Replies to requests for interpretation of the chemical standards in the EN 71-series Scurit des jouets - Interprtations - Partie 2: Rponses aux demandes dinterprtation des normes chimie de la s

3、rie EN 71 Sicherheit von Spielzeug - Interpretationen - Teil 2: Antworten auf Anfragen zur Interpretation der chemischen Normen in der Normenreihe EN 71 This Technical Report was approved by CEN on 17 April 2017. It has been drawn up by the Technical Committee CEN/TC 52. CEN members are the national

4、 standards bodies of Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, Former Yugoslav Republic of Macedonia, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Norway, Poland, Portugal, Romania, Serbia,

5、 Slovakia, Slovenia, Spain, Sweden, Switzerland, Turkey and United Kingdom. EUROPEAN COMMITTEE FOR STANDARDIZATION COMIT EUROPEN DE NORMALISATION EUROPISCHES KOMITEE FR NORMUNG CEN-CENELEC Management Centre: Avenue Marnix 17, B-1000 Brussels 2017 CEN All rights of exploitation in any form and by any

6、 means reserved worldwide for CEN national Members. Ref. No. CEN/TR 15371-2:2017 ENational forewordThis Published Document is the UK implementation of CEN/TR 15371-2:2017. It supersedes PD CEN/TR 15371-2:2015, which is withdrawn.The UK participation in its preparation was entrusted to Technical Comm

7、ittee CW/15, Safety of toys.A list of organizations represented on this committee can be obtained on request to its secretary.This publication does not purport to include all the necessary provisions of a contract. Users are responsible for its correct application. The British Standards Institution

8、2017 Published by BSI Standards Limited 2017ISBN 978 0 580 96335 3ICS 97.200.50Compliance with a British Standard cannot confer immunity from legal obligations. This British Standard was published under the authority of the Standards Policy and Strategy Committee on 30 June 2017.Amendments/corrigend

9、a issued since publicationDate Text affectedPUBLISHED DOCUMENTPD CEN/TR 15371-2:2017TECHNICAL REPORT RAPPORT TECHNIQUE TECHNISCHER BERICHT CEN/TR 15371-2 May 2017 ICS 97.200.50 Supersedes CEN/TR 15371-2:2015English Version Safety of toys - Interpretations - Part 2: Replies to requests for interpreta

10、tion of the chemical standards in the EN 71-series Scurit des jouets - Interprtations - Partie 2: Rponses aux demandes dinterprtation des normes chimie de la srie EN 71 Sicherheit von Spielzeug - Interpretationen - Teil 2: Antworten auf Anfragen zur Interpretation der chemischen Normen in der Normen

11、reihe EN 71 This Technical Report was approved by CEN on 17 April 2017. It has been drawn up by the Technical Committee CEN/TC 52. CEN members are the national standards bodies of Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, Former Yugoslav Republic of Mace

12、donia, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Norway, Poland, Portugal, Romania, Serbia, Slovakia, Slovenia, Spain, Sweden, Switzerland, Turkey and United Kingdom. EUROPEAN COMMITTEE FOR STANDARDIZATION COMIT EUROPEN DE NORMALISA

13、TION EUROPISCHES KOMITEE FR NORMUNG CEN-CENELEC Management Centre: Avenue Marnix 17, B-1000 Brussels 2017 CEN All rights of exploitation in any form and by any means reserved worldwide for CEN national Members. Ref. No. CEN/TR 15371-2:2017 EPD CEN/TR 15371-2:2017CEN/TR 15371-2:2017 (E) 2 Contents Pa

14、ge European foreword . 3 0 Introduction 4 0.1 Interpretations and no-action decisions 4 0.2 Requests for interpretation . 4 0.3 Answers to requests for interpretations 5 1 Scope 6 2 EN 71-3:2013, Safety of toys Part 3: Migration of certain elements 6 2.1 4.1 Toy material categories - “stickers” (int

15、erpretation) . 6 2.2 4.1 Toy material categories - “erasers” (interpretation) 7 2.3 4.1 Toy material categories (interpretation) 7 PD CEN/TR 15371-2:2017CEN/TR 15371-2:2017 (E) 3 European foreword This document (CEN/TR 15371-2:2017) has been prepared by Technical Committee CEN/TC 52 “Safety of toys”

16、, the secretariat of which is held by DS. Attention is drawn to the possibility that some of the elements of this document may be the subject of patent rights. CEN and/or CENELEC shall not be held responsible for identifying any or all such patent rights. This document supersedes CEN/TR 15371-2:2015

17、. CEN/TR 15371, Safety of toys Interpretations, is currently composed with the following parts: Part 1: Replies to requests for interpretation of EN 71-1, EN 71-2, EN 71-8 and EN 71-14; Part 2: Replies to requests for interpretation of the chemical standards in the EN 71-series. PD CEN/TR 15371-2:20

18、17CEN/TR 15371-2:2017 (E) 4 0 Introduction 0.1 Interpretations and no-action decisions This Technical Report contains replies to requests for interpretations concerning the understanding of clauses in the chemical standards in the EN 71 series: EN 71-3: Migration of certain elements; EN 71-4: Experi

19、mental sets for chemistry and related activities; EN 71-5: Chemical toys (sets) other than experimental sets; EN 71-7: Finger paints Requirements and test methods; EN 71-9: Organic chemical compounds Requirements; EN 71-10: Organic chemical compounds Sample preparation and extraction; EN 71-11: Orga

20、nic chemical compounds Methods of analysis; EN 71-12: N-Nitrosamines and N-Nitrosatable substances; EN 71-13: Olfactory board games, cosmetic kits and gustative games. The replies concern those requests that have resulted in an interpretation or a decision that no action is required as the standard

21、is sufficiently clear. An interpretation does not have the same status as the text of the standard, nor can it overrule the text of the standard. However, following an interpretation should give assurance that the relevant clause of the standard has been correctly applied. An interpretation should o

22、nly be regarded as a clarification of the meaning of the standard such that stakeholders can apply it correctly in a conformity assessment. An interpretation is not an assessment of the requirement in the standard - it is only a strict interpretation of the meaning of the text. Disclaimer The interp

23、retations have been derived by expert groups of CEN/TC 52. The information contained herein is for guidance only and does not reflect the formal approval by CEN or CEN member bodies. It should be noted that the interpretations are neither part of any standard nor have been referenced in the Official

24、 Journal of the European Union. 0.2 Requests for interpretation Requests for interpretations may be submitted by a CEN member body through its national committee or by a CEN/TC 52 liaison (but not directly by an individual or a company) - in accordance with the interpretation protocols agreed by CEN

25、/TC 52. The requests are then channelled to the relevant CEN/TC 52 working party, which will then deal with the request. A request for an interpretation may lead to: a) An interpretation of the standard: This should reflect a reasonable interpretation of how the standard should be used, taking into

26、account: PD CEN/TR 15371-2:2017CEN/TR 15371-2:2017 (E) 5 1) the wording of the standard; 2) the rationale of the standard; 3) the history of the standard. b) A no-action decision: This is applicable when it is agreed that the standard appropriately specifies how a toy shall be assessed. c) A proposa

27、l for an amendment of the standard: This is applicable when it is agreed that the standard is deficient in some way. NOTE Interpretation and no-action decisions are published in CEN/TR 153712, which will be updated on a regular basis. Proposals for amendments will be progressed as new work item prop

28、osals in accordance with CEN rules. 0.3 Answers to requests for interpretations Since requests for interpretations are submitted through a CEN member body or a CEN/TC 52 liaison, it is assumed that they will keep themselves informed about decisions concerning the request and its progress and will th

29、emselves inform the originator of the request as appropriate. PD CEN/TR 15371-2:2017CEN/TR 15371-2:2017 (E) 6 1 Scope The purpose of this Technical Report is to provide replies to requests for interpretations of actual chemical standards in the EN 71 series: EN 71-3: Migration of certain elements; E

30、N 71-4: Experimental sets for chemistry and related activities; EN 71-5: Chemical toys (sets) other than experimental sets; EN 71-7: Finger paints Requirements and test methods; EN 71-9: Organic chemical compounds Requirements; EN 71-10: Organic chemical compounds Sample preparation and extraction;

31、EN 71-11: Organic chemical compounds Methods of analysis; EN 71-12: N-Nitrosamines and N-Nitrosatable substances; EN 71-13: Olfactory board games, cosmetic kits and gustative games. 2 EN 71-3:2013, Safety of toys Part 3: Migration of certain elements 2.1 4.1 Toy material categories - “stickers” (int

32、erpretation) Question The question relates to the categorization of “stickers” under 4.1 Toy material categories of EN 71-3. Stickers are often composed of paper/plastic and glue. Sticky/liquid glue as such falls within category II of the EN 71-3 (liquid or sticky material), while paper/plastic fall

33、s within category III (scraped-off material). We have considered two situations: stickers already on the toy (glue is not accessible to children since the sticker is already on the toy); stickers provided as such to children (glue is accessible once the sticker is removed from its backing). We would

34、 like to know whether the sticker materials in the two above cases shall be considered independently for their categorization (i.e. category II for the glue and category III for the paper) or whether the whole sticker should be considered for the categorization. Reply Stickers which are already plac

35、ed on the toy (glue is not accessible) should be tested as scraped-off material (polymer/paper: category III). Stickers provided as such to the child with possible exposure to the thin sticky part (including temporary tattoos), should also be evaluated according to category III as a whole. REQ 001-1

36、3 (UNI, Italy) PD CEN/TR 15371-2:2017CEN/TR 15371-2:2017 (E) 7 2.2 4.1 Toy material categories - “erasers” (interpretation) Question The question relates to the categorization of “erasers” under 4.1 Toy material categories of EN 71-3. Erasers classified as toys which are made of polymeric material r

37、eleases some particles when used. In which toy material category should we classify erasers? Reply Erasers made of polymeric material and classified as toys (see commission guidance document 15) and their released particles are categorized as category III toy material. REQ 002-13 (UNI, Italy) 2.3 4.

38、1 Toy material categories (interpretation) Question How should highly viscous liquids (e.g. approaching solidity) which would fall into category II for the purposes of EN 71-3, be distinguished from pliable modelling materials which would fall into category I? The following example has been given: I

39、f a portion of a highly viscous liquid category II was removed there would be little evidence of this within a short period of time. The substance would flow into the space previously occupied and create a new level. A category I modelling material would hold its shape if a portion was removed. See

40、example below: Figure 1 PD CEN/TR 15371-2:2017CEN/TR 15371-2:2017 (E) 8 It might appear that viscous liquid paints (category II) have a similar consistency to pliable modelling materials category I (see table below). Moreover in this case also very viscous liquids might leave dry residues on the han

41、ds of the user (see chart CEN/TC 52/WG 5 N 578). Table 1 Cross-reference table for determining category Reply It is recommended to use Table 1 under Clause 4.1 from the EN 71-3:2013+A1 which categorizes the toy materials according to their application. If the toy material is a modelling material the

42、n it should be evaluated as a category I material; If the toy material is paint (other than compressed paint tablets) then it should be evaluated as a category II material, even for high viscous paint. REQ 03-15 (BSI, UK) PD CEN/TR 15371-2:2017This page deliberately left blankBSI is the national bod

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