Product safety
How to control the safety of consumer products
Consumers in Europe expect that the products they buy and use are safe, and according to the current European legislation they are entitled to do so. Nevertheless, consumer products are involved in the majority of home and leisure accidents, and the media often report about product recalls of defective products. This article deals with the safety of non-food consumer products in the European Union. Recommendations are presented for the implementation of safety criteria in quality management systems.
Risk control
Consumer goods differ from products for industrial use in that the provider is almost entirely out of control after the product is sold. The product will probably be used by unskilled users, it may be used for tasks never thought of by the designer, children will come into contact with the product unsupervised, and the prescribed maintenance is unlikely to be executed at all. Nevertheless, the provider is usually held responsible of the safety of his product and the consequences of accidents, might they happen under the afore mentioned circumstances. Both the European Product Liability Directive (1985) and the European General Product Safety Directive (1992) give the enforcement bodies and consumers, respectively, considerable powers to impose expensive measures upon product providers, e.g. product recalls and liability claims. It is therefore imperative to know the risks involved and to control them through the entire life cycle of the product, i.e from design to delivery; the General Product Safety Directive even demands that the safety of the product be monitored after sale.
The easiest way to control the risk is to distribute only products which comply with generally accepted standards, and produce and deliver them under the regime of formally accredited quality control systems. In this article only the safety of the product design is dealt with; recommendations for the manufacturing and distribution of products can be found elsewhere.
Safety criteria for consumer products
In Europe, the safety of non food consumer products is largely controlled by European standards. Several standards are related to European Directives, e.g. the Low Voltage Directive (for electrotechnical equipment) and the Personal Protective Equipment Directive. Standards are not legally binding, but, when connected to a European Directive, they are an official touchstone for compliance with the contents of the Directive. This means that a product that meets the requirements of the standard is considered safe by the national enforcement bodies. Only when the product provider is aware of, or could have been aware of deficiencies in the standard, can he be held liable for the damage caused due to this deficiency. The "could have been aware of" clause relates to the obligation to screen the relevant literature and monitor the use of the product after sale.
It follows that the basic strategy to control the risk of purchasing decisions is to make the product under consideration comply with the applicable European safety standards. Unfortunately, such standards are not always available. When they are, it is easy to find them, e.g. by consulting a national standardization body or a reputable test house. In case no official European standards are applicable, alternative strategies have to be considered. An important principle then is to make use of safety requirements which have been developed and are supported by groups of independent experts with varied backgrounds. In practice, this means that most national standards are acceptable, unless they are known to be deficient. The same holds true for the criteria used in well-established certification schemes (which -by the way- are often standards). The term "well-established" can be interpreted as being accredited by an official accreditation body. Useful information about the "reliability" of certain safety criteria and certification schemes can often be obtained from experts in research institutes, test houses and consumer organizations. When the product under consideration is covered by a European Directive, there exist notified bodies, i.e. test houses assigned by national governments, which are authorized to decide and declare whether the product is safe enough.
Risk assessment of consumer products
When reliable standards or certification criteria are not available, the product should be subjected to a thorough risk assessment in order to determine whether it can safely be sold to consumers. Risk assessment techniques for industrial products, like machines, are well-elaborated; for consumer products, however, the development of risk assessment procedures lags behind. Studies by the Consumer Safety Institute (CSI) in the Netherlands have shown that common risk assessment techniques need considerable adaptation, in order to take account of the deviating circumstances under which consumer products are being used. The Institute has implemented these adaptations and described the results in a detailed risk assessment procedure for consumer products (Van Aken et al., 1996). The procedure consists of three steps, in which the following questions are answered:
- what can happen with this product?
- which are the possible consequences (damage, injury)?
- how likely are these to happen?
This approach results in an overview of the involved risks and their relative importance, on the basis of which priorities can be set to improve the safety of the product where necessary.
A key element of CSI's risk assessment procedure is the hazard-oriented approach, which makes it possible to assess the safety of products for which no standards are available, even in the absence of recorded accident and injury data.
Developing safety criteria and test methods
According to the hazard-oriented approach, the safety criteria and test methods in well-established standards can be transferred to other products for which no standards are available, e.g. new and innovative designs. In combination with an analysis of (possible) use patterns and user characteristics this makes it possible to draft adequate safety criteria in many cases where standard are not (yet) available.
Examples
A few examples may illustrate the foregoing.
Non-food premium product
A food company wants to start a sales action in which consumers can get a non-food premium product. The premiums are imported from outside the European Union. Because a food company has no expertise in the safety of non-foods, is will have to take special precautions with regard to the safety of the design, the manufacturing process and the safety aspects of the distribution. When the product has not been designed in accordance with the relevant European standard, a risk assessment should be done, and the recommended design improvements implemented. The manufacturing process should be under control of an accredited quality management system, and the transport from the plant to the customer should not introduce new risks for the customer.
Toy with special features
A toy importing company wants to sell a new kind of toy in Europe, which has some special features not covered by the European toy standard. Since the product falls under the European Toy Directive, the company has to get an approval from one of the notified bodies (see above) for toys.
Author, references and further reading
Biography of the author
Willem van Weperen (1952) is managing director of the Keurmerkinstituut (Certification Institute) in Amsterdam (NL), an independent organisation for the testing of the quality and safety of products, services and accommodations for consumers. The Keurmerkinstituut operates a number of certification and conformity assessment systems for consumer products, services and accommodations.
After graduating from university (experimental physics), the author joined a certification institute for consumer products. In 1997 this institute became part of the Keurmerkinstituut. From 1985 until the end of 1997 the author was head of product safety at the Consumer Safety Institute in Amsterdam (NL), an independent body for research and prevention in home and leisure safety.
References and further reading
Van Aken, D., W.A.M. Hoefnagels, A. van Randen, M. Sonneveld. Handboek ontwerpen van veilige producten (Handbook for the design of safe products, in Dutch). Lemma, Utrecht, 1996. ISBN 90-5189-566-6.
Van Weperen, W. Guidelines for the development of safety-related standards for consumer products. Accident Analysis & Prevention 25: 11-17, 1993.