1、raising standards worldwideNO COPYING WITHOUT BSI PERMISSION EXCEPT AS PERMITTED BY COPYRIGHT LAWBSI Standards PublicationPD CEN/TR 15371:2013Safety of toys Replies torequests for interpretation ofEN 71-1, EN 71-2, and EN 71-8Copyright European Committee for Standardization Provided by IHS under lic
2、ense with CENNot for ResaleNo reproduction or networking permitted without license from IHS-,-,-PD CEN/TR 15371:2013 PUBLISHED DOCUMENTNational forewordThis Published Document is the UK implementation of CEN/TR 15371:2013. It supersedes PD CEN/TR 15371:2009, which is withdrawn.The UK participation i
3、n its preparation was entrusted to Technical Committee 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 correc
4、t application. The British Standards Institution 2013. Published by BSI Standards Limited 2013.ISBN 978 0 580 77209 2 ICS 97.200.50 Compliance with a British Standard cannot confer immunityfrom legal obligations.This Published Document was published under the authority of the Standards Policy and St
5、rategy Committee on 31 March 2013.Amendments issued since publicationDate Text affectedCopyright European Committee for Standardization Provided by IHS under license with CENNot for ResaleNo reproduction or networking permitted without license from IHS-,-,-PD CEN/TR 15371:2013TECHNICAL REPORT RAPPOR
6、T TECHNIQUE TECHNISCHER BERICHT CEN/TR 15371 February 2013 ICS 97.200.50 Supersedes CEN/TR 15371:2009English Version Safety of toys - Replies to requests for interpretation of EN 71-1, EN 71-2, and EN 71-8 Scurit des jouets - Rponses aux demandes dinterprtation de lEN 71-1, lEN 71-2 et lEN 71-8 Sich
7、erheit von Spielzeug - Antworten auf Anfragen zur Interpretation von EN 71-1, EN 71-2 und EN 71-8 This Technical Report was approved by CEN on 13 August 2012. It has been drawn up by the Technical Committee CEN/TC 52. CEN members are the national standards bodies of Austria, Belgium, Bulgaria, Croat
8、ia, 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, Slovakia, Slovenia, Spain, Sweden, Switzerland, Turkey and Un
9、ited Kingdom. EUROPEAN COMMITTEE FOR STANDARDIZATION COMIT EUROPEN DE NORMALISATION EUROPISCHES KOMITEE FR NORMUNG Management Centre: Avenue Marnix 17, B-1000 Brussels 2013 CEN All rights of exploitation in any form and by any means reserved worldwide for CEN national Members. Ref. No. CEN/TR 15371:
10、2013: ECopyright European Committee for Standardization Provided by IHS under license with CENNot for ResaleNo reproduction or networking permitted without license from IHS-,-,-PD CEN/TR 15371:2013CEN/TR 15371:2013 (E) 2 Contents Page Foreword 4 0 Introduction 5 0.1 Interpretations and no-action dec
11、isions .5 0.2 Requests for interpretation .5 0.3 Answers to requests for interpretations .5 1 Scope 6 2 EN 71-1:2011 - Safety of toys Part 1: Mechanical and physical properties 6 2.1 3.41 and 3.42 Projectile toys (no action decision) .6 2.2 3.41, 3.42 and 7.7 Projectile toys (no action decision) 6 2
12、.3 4.3 Flexible plastic sheeting (no action decision) 8 2.4 4.4 Toy bags (no action decision) 9 2.5 4.5 Glass (no action decision) .9 2.6 4.10.1 c) folding and sliding mechanisms (no action decision) .9 2.7 4.14.2 Masks and helmets (no action decision) 10 2.8 4.15.1.4 Stability (interpretation) 11 2
13、.9 4.15.1.4; 8.23.1 Stability (interpretation) . 11 2.10 4.15.1.6 c) Transmission and wheel arrangement (no action decision). 14 2.11 4.15.1.6 d) Transmission and wheel arrangement (no action decision) 15 2.12 4.17 Projectiles (no action decision) 16 2.13 4.19 Percussion caps (no action decision) .
14、18 2.14 4.20 Acoustics (Re: Squeeze toys) (no action decision) . 18 2.15 5 Toys intended for children under 36 months (re: inflatable toys) (interpretation) 19 2.16 5.1 General requirements (re: small parts) (interpretation) . 19 2.17 5.1 General requirements (re: small parts) (interpretation) . 19
15、2.18 5.1 General requirements (re: fuzz) (no action decision) 19 2.19 5.1 General requirements (re: plastic whiskers) (interpretation) 20 2.20 5.1 General requirements (no action decision) 20 2.21 5.1 e) General requirements (re: glued wooden toys) (no action decision) . 21 2.22 5.1 e) General requi
16、rements (re: paper, varnish) (interpretation) 21 REQ 092-09 (PKN - Poland) . 22 2.23 5.7 Glass and porcelain (interpretation) 22 2.24 5.8 Shape and size of certain toys (re: accessibility) (interpretation) 22 2.25 5.8 Shape and size of certain toys (interpretation) 23 2.26 5.8 Shape and size of cert
17、ain toys (re: squeeze toys) (no action decision) 23 2.27 5.10 Small balls (no action decision) . 23 2.28 6 Packaging (no action decision) . 27 2.29 7.2 Toys not intended for children under 36 months 8.23.1 Stability (interpretation) Question (UNI, Italy) EN 71-1 requires, for the stability test, to
18、“load the toy in the most onerous position with a mass on its standing or sitting surface”. Our interpretation of this requirement is “Load the toy in the most onerous position on the standing or sitting surface, in such a way the mass is perpendicular to the standing or sitting surface and that the
19、 vertical projection of the base of the test mass is fully enclosed in the sitting surface. If the standing or sitting surface is narrower than the test mass, the centre of the test mass shall be positioned along the axis of the seat.” Copyright European Committee for Standardization Provided by IHS
20、 under license with CENNot for ResaleNo reproduction or networking permitted without license from IHS-,-,-PD CEN/TR 15371:2013CEN/TR 15371:2013 (E) 12 Applying this interpretation, a correct position to place the test mass for the front stability is shown in the following pictures (please, do not co
21、nsider the position of the toy on the inclined plane, it is just an example). If we do not apply this interpretation every laboratory can try to find any improbable sitting surface like in the following examples: We consider that all the above examples represent a not correct way to perform the test
22、: in the first row example, the mass is not perpendicular to the sitting surface, in the second and in the third rows, the mass base is outside the sitting surface. In the third row, someone can argue that the ring allows the placing of the mass without any external support, but if we consider apply
23、ing this interpretation, we will again have problems. Actually, EN 71-1 Figure 21 does not define the sides of the test mass. Since the test mass does not need to be a perfect cylinder, also the test mass for the dynamic test defined in Figure 23 may be used. Since the position of the test mass on r
24、ide on Copyright European Committee for Standardization Provided by IHS under license with CENNot for ResaleNo reproduction or networking permitted without license from IHS-,-,-PD CEN/TR 15371:2013CEN/TR 15371:2013 (E) 13 toys with armrest may be significantly influenced (if we agree with this inter
25、pretation) by the sides of the test mass, we will have for sure different test results, depending on the kind of the test mass used. We can also have even more improbable test conditions like the following: According to our opinion, the correct interpretation is “load the toy in the most onerous pos
26、ition on the standing or sitting surface, in such a way the mass is perpendicular to the standing or sitting surface and that the vertical projection of the base of the test mass is fully enclosed in the sitting surface. If the standing or sitting surface is narrower than the test mass, the centre o
27、f the test mass shall be positioned along the axis of the seat“. Thus between the two positions shown in the following examples, in case we are considering the frontal stability, it is the second (the one with the test mass with its base in contact with the front edge of the seat) to be considered a
28、s the most onerous condition (in the other one, the test mass is just centred on the seat, and thus this is not the most onerous position). Nevertheless, allowing laboratories to place the mass with its base outside the sitting surface would lead to have no more repeatable tests. Copyright European
29、Committee for Standardization Provided by IHS under license with CENNot for ResaleNo reproduction or networking permitted without license from IHS-,-,-PD CEN/TR 15371:2013CEN/TR 15371:2013 (E) 14 We also consider that a stability test for ride on toys with child rings or armrests should be developed
30、, like the test method to test ride on toys with backrest, which is currently being developed by TG 6 (We suggest that for armrest, the test mass should be further decreased to 9 kg). Question (BSI, United Kingdom) The clause states “Load the toy in the most onerous position” Can this be clarified a
31、s to whether the weight/mass is loaded in the most onerous position or the toy is placed in the most onerous position with the test mass located in the “normal” position of use? Comments/proposal for an answer: Believed that the test mass should be placed on the seat (or standing position) to the ex
32、tremity of the seat, but within the confines of the seat, i.e. not overhanging the seat. Also, the test mass should remain perpendicular to the plane of the seat, when placed on the 10 slope. Interpretation Before placing the toy on the slope, the mass shall be placed on the sitting or standing surf
33、ace so that the main axis of the mass remains as close as vertical as possible without any additional support between the mass and the sitting or standing surface. If the sitting or standing surface is larger than the base of the test mass, the test shall be performed placing the mass on the sitting
34、 or standing surface in the most onerous position(s) with regards to stability and shall remain within the sitting or standing surface. It is allowed to use e.g. tape, straps, etc. to maintain the mass in position when the toy is placed on the slope. REQ 070-06 (UNI, Italy); REQ 074-07 (BSI, United
35、Kingdom) 2.10 4.15.1.6 c) Transmission and wheel arrangement (no action decision) Question During testing of a battery-operated ride on car (shown below), it was noted that there was a gap of approximately 6 mm between a wheel and the adjacent motor housing (see illustration). It is clear from 4.15.
36、1.6 c) of EN 71-1 that the product fails: Text of standard c) Spaces between the wheels and the body or parts of the body (e.g. mudguards) shall also allow a 12 mm diameter rod to be inserted if they allow a 5 mm diameter rod to be inserted. Is this an accurate understanding of the standard? Copyrig
37、ht European Committee for Standardization Provided by IHS under license with CENNot for ResaleNo reproduction or networking permitted without license from IHS-,-,-PD CEN/TR 15371:2013CEN/TR 15371:2013 (E) 15 View of back of car 5 mm plug gauge inserted in gap The UK committee agreed that the product
38、 apparently failed the technical requirements of 4.15.1.6 c) of EN 71-1 and that that subclause was applicable to the toy in question and has asked me to forward this enquiry to CEN TC52/TG1 for a further interpretation and action as necessary. Reply The standard adequately treats this case. The 5/1
39、2 mm requirement only applies to areas capable of crushing fingers or other parts of the body if entrapped considering the normal and foreseeable use of the toy. Reference is made to EN 71-1, Annex A, second sentence of A.20: “the requirements are also intended to address the hazards associated with
40、 chain transmissions and wheel arrangements capable of crushing fingers and other parts of the body, if entrapped”. REQ 054-05 (BSI, United Kingdom) 2.11 4.15.1.6 d) Transmission and wheel arrangement (no action decision) Question Subclause 4.15.1.6 d) states: “Tricycles, provided with an attached h
41、andle used for pushing the child, shall be constructed in such a way as to prevent entrapment of the childs feet in the pedals, etc. whilst being pushed, (e.g. free-wheeling mechanism or foot rests).” If a free-wheeling mechanism is present, 4.15.1.5 requires a mechanically propelled toy to have a b
42、raking device. It is very difficult for a manufacturer to add a brake to a tricycle. Therefore, one possible solution (in my opinion) is to manufacture the tricycle with the option of having the front wheel (with pedals) set as either a fixed drive or free-wheeling, with accompanying instructions cl
43、early informing the parent to set it as free-wheeling if the parent handle is attached, or fixed drive if the handle is not attached (I have seen several like this on the market). However, 4.15.1.5 excludes “toys where hands or feet provide the motive power to the driving wheel(s) via direct transmi
44、ssion”. It is our belief that this exclusion was written prior to the addition of 4.15.1.5 d) in the 1998 edition, when all tricycles were of the traditional fixed wheel design. This exclusion is therefore, in my opinion, not valid if the tricycle has a free-wheel mode. A.20 also excludes tricycles
45、with pedals on the front wheel, but again, I believe this rationale was written with only fixed wheel tricycles in mind. Copyright European Committee for Standardization Provided by IHS under license with CENNot for ResaleNo reproduction or networking permitted without license from IHS-,-,-PD CEN/TR
46、 15371:2013CEN/TR 15371:2013 (E) 16 The point here is that a retailer wishes to supply a free-wheeling tricycle with a parent handle and no brake. If the parent handle is removed, the child will be riding a free-wheeling toy with no means of braking, usually performed by the child putting his feet o
47、n the pedals (I do not hold with a suggested view that the child can brake the tricycle by putting his feet on the ground, since this is likely to lead to foot entrapment by the frame or rear wheels. Remember that 4.15.1.6 d) requires a tricycle with a parent handle to have foot rests, for example,
48、for the very reason of keeping the childs feet away from moving parts). Would the group agree that the exclusion in 4.15.1.5 is not valid in this instance? Reply The standard, as it is currently, adequately addresses this case. This kind of toy would require a brake. REQ 055-05 (BSI, United Kingdom)
49、 2.12 4.17 Projectiles (no action decision) Question Our question is that whether the toy product said to be DRONE (containing plastic darts with resilient material point and a plastic target, and the darts are designed to be thrown by hand of a child upon the target) is considered as a “projectile toy” ac
