Product Safety Projects
CPSC and Manufacturer Cooperation – ATV Label Warnings and Age Labeling
Miller Engineering has worked directly with the CPSC and manufacturers to assist in product development or to help remedy a problem with existing products. For example, on behalf of four manufacturers of All Terrain Vehicles (ATV’s), we developed and tested (among 1000 users) the warning labels which are now mandatory on all ATV’s sold in the USA (Included were: Honda, Yamaha, Polaris, Suzuki). This label appears in the following illustration: see ATV Label
A specialty of Miller Engineering is the design and testing of product labels. This includes: on-product, attached to product, within operator manuals, within instruction manuals, on packaging and within packaging on individually wrapped package contents. Below are some related projects oriented towards child safety.
Child Plastic Bag and Package Materials Suffocation or Choking
In several states, standards require labeling of plastic bags which have the opportunity to come into contact with small children. Conceptually, if a small child’s head can fit within such a bag, it may need to be labeled with a warning. Additionally, if a plastic is of a small mil thickness which could contour to a child’s facial breathing area (such as a dry cleaning bag), it may also need to be labeled with a warning. Foam type inserts and “peanut” type cushioning materials also present choking potential if not immediately and properly disposed of. We have developed warnings for immediate and proper disposal of plastic bags, sheet plastic and all packaging parts to prevent child contact.
To assist a major manufacturer of computer products, Miller Engineering developed a corporate wide policy-criteria for warning labels on all plastic bags used in packaging any of their products or package inserts. Such a policy will assure compliance with all existing state, Federal and international standards. These warnings are available in five different languages to reflect the broad base of marketing which characterizes this company.
Electronic Game Controller & Repetitive Trauma in Children
It may be too early to appreciate the health consequences to children of extreme time spent using electronic game technology. One consideration is the eventual development of hand/wrist repetitive trauma caused by specific designs of game controllers. While there are no known research findings relative to children injuries as of yet, Miller Engineering has recommended preemptive warnings to parents about taking the same precautions in usage as might be recommended for the adult using products which have the potential for cumulative repetitive trauma injuries.
Child Choking from Toys/Dolls
Current CPSC standards have addressed the normal choking hazards of toys having small parts which can separate from the main product, or which are part of the many components making up a game or assembly package, such as Lego blocks. With the availability of electronic dolls and complex soft toys, additional potential hazards have been introduced.
In performing safety analyses for some manufacturers, Miller Engineering has recommended design changes where easy access to electronic parts and battery chambers is possible. Sometimes configurations of limbs and accent features of soft toys present objects which can become stuck in a baby’s throat or block the breathing passage, possibly necessitating a redesign.
Child Strangulation – Toys, Mini-Blinds, and Packaging
Strings and rope capable of child strangulation appear from unexpected sources. Miller Engineering has engaged in accident reconstruction and product redesigns in each of the above named areas. Mini-blinds have hidden strings which are necessary to functionality, but have the capability to accidentally engage children left unsupervised to play in their vicinity. We participated in developing the warnings which are now provided on these products.
Strings which are a part of toys are no different from ties that are used as part of the packaging for toys and many other products not intended for younger children. While the length of pull and suspension strings on toys have standards, we have recommended to manufacturers of certain child susceptible products that either package ties be limited in length or warnings be placed relative to immediate and proper disposal of all packaging parts to prevent child contact.
Child Choking Hazard of Food
Being a necessity which cannot be eliminated, nearly any food has the potential for choking if not properly served and its consumption not sufficiently supervised. There are certain foods which have statistically been pointed out through the NEISS system and pediatricians as having higher levels of risk for children during consumption, i.e., peanuts, whole grapes, and hot dogs.
Currently there are no government agencies known to us which investigate, regulate or take responsibility for child food choking hazards, although CPSC has regulated toy choking hazards. Manufacturers producing those products particularly susceptible to child choking have been advised to review whether their particular product justifies any change in formulation or warnings on exterior packages.
A few food product manufacturers have in the past few years begun to include such warnings on their products. Included in such warnings have been issues of parent supervision, form and quantities being served, danger of older children feeding younger siblings, and location and limitations of levels of activities while consuming food.
Infant Carriers/Child Car Seats
State laws typically require infants to be contained in car seats and Federal/Consensual standards establish criteria which qualifying car seats must pass. Specific features of some manufacturer’s car seat models have resulted in mandatory or voluntary notifications and recalls by the CPSC. A different aspect of this issue is the interaction of products labeled as “infant carriers” which are not intended and should never be used for child restraint in a car.
The difficulty which manufacturers and retailers have had is the education of the public who present themselves to buy such a product for their child, grandchild, or someone else’s child (such as for a present). While a child seat may cost $50 , the lighter usage infant car carrier may cost only $25, leading people to the lower price. Because they appear to serve the similar function of carrying a child, they may be very similar in appearance.
Miller Engineering researched these two products to find that to the lay purchaser they may appear so similar that they cannot be distinguished from their features. When this is the case, warnings relative to their proper intended use are essential, both at the point of sale and on the products themselves. this issue has been explored in our publication “Communicating a Safety-Critical Limitation of an Infant Carrying Product”.
Entertainment Centers and TV Stands
Entertainment centers and TV stands have been frequently associated with tipovers involving children. A few U.S. groups have started to address this issue from a standards perspective, and international safety groups have created stability standards.
Miller Engineering has done independent testing on such furniture to determine their susceptibility to tipover by children playing in and around such furniture. Dynamic testing is probably necessary to establish reasonable standards in that static children weights themselves may not take into account the activities which lead to tipover accidents.
ASTM F-15 Child Toys and Furniture Committee
The most prolific organization in the USA developing standards relative to children is the American Society for Testing Materials. This organization has taken it on itself to set up an elaborate structure of committees to address the construction and design of toys, furniture, and play equipment and has radically improved their safety.
Dr. Miller is a member of the ASTM F-15 Main Committee and has an opportunity to review, comment and vote on the various standards under development or in revision. In the past few years, those standards have included playground swings, sliding boards, matches, bunk beds, child seating, dressers and entertainment centers. Manufacturers play a vital part in the development of these new standards. The identification of child products as new candidates for the standards making process has been made possible by the more sophisticated injury surveillance collection systems, such as NEISS. Prior to such data availability the products associated with many child injuries and fatalities did not exist and were unknown to both government, consumer associations and manufacturers.
Smoke Detectors and Child Fire Fatalities
Being asked to address reconstruction issues in any serious child injury or fatality matter is unpleasant. Nevertheless, Miller Engineering usually has at least one project in progress where a smoke detector could or should have saved a life, often a child’s life. Our research has indicated that the limitations of these and gas detection devices in general are sometimes unknown or uncommunicated. With smoke detectors, there is likely to be a misinterpretation of their capabilities which has lead to a very false confidence regarding their ability to protect. We believe that their continued voluntary use in homes and mandatory use in some commercial and rental units is fully justified. However, as opposed to a sprinkler type system, which is a “passive” type safety device which doesn’t require human intervention for it to provide its protection, the household smoke or other gas detector is an “active” type device. “Active” means that the individuals involved must properly sense, quickly interpret and adequately respond to the warning it emits. As with any “detection” device, the human response chain cannot begin unless the detector itself is scientifically capable of responding in the manner intended. Smoke detectors require human installation, maintenance, understanding and action.
Parents often have the false impression that smoke detectors are the magic which will save their children’s lives in the event of a fire without their intervention, but a parents first response must be to get children out of the building immediately before doing anything else. A simple rule, but its violation has lead to unnecessary fatalites. Smoke can easily be detected perceptually by an awake and alert individual before a smoke detector activates and thus a detector may actually offer late rather than early detection. In cases where parents have been absent, remote in a building, or in a compromised state when fire breaks out, it becomes common to blame the smoke detectors for harm to children. This over-reliance and over-blame on smoke detectors may be a generalizable national socio-preventive health problem.
Miller Engineering’s current smoke detector research is concerned with the false security and scientific limitation issues. The essence of this concern is the experience persons have had with smoke detectors being easily and/or often activated by overheating foods and cooking smoke/vapors. While a cause of irritation to consumers, it also gives the positive feedback that such smoke detectors are extremely sensitive to any type of overheating or smoke in the environment. It is this false premise that might be dangerous. Namely, it appears that the most common smoke detector’s sensitivity to cooking type odors, vapors, and smoke is much higher than to the smoke that would originate from, for example, furniture beginning to smoke or burn because of ignition by a lit cigarette. This means that it may take 10 to 20 minutes for a detector to activate with this type of smoke, where in a kitchen setting the activation time may be less than a minute. Consequently, by the time activation occurs, the smoke from a smoldering fire may quickly reaching the critical survival point.