RE: PACIFIERS & LEASHES

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Thank you, again, Debbie Ramos for the update from Will at the CPSC.

First off, toy tethers and pacifier clips are generally not considered to be toys themselves. There are sometimes exceptions, but generally these products are not considered subject to the ASTM F963 Toy Standard.

For small parts use and abuse testing, it comes down to what kinds of adornments exist on the tether, leash, or the pacifier clip. If there are buttons, snaps, clips, zippers, or any hard material embedded into the product, then it will require small parts use and abuse testing. So, the products featured in photos 3, 4, and 5 will all need small parts testing from a CPSC-accepted laboratory. (This all assumes, of course, that the product is intended for a child under 3 years of age, which, presumably, all of these are.)

On the other hand, if the entire product is made from fabric and elastic, as you show in photo number 1, then no small parts use and abuse testing would be needed. This is because the potential hazard of small choking parts is not present as it is in the examples with clips and snaps. Note, textiles are not considered to be small parts for purposes of our requirements.

In addition, manufacturers of both product areas should be cognizant of the risk of entanglement and strangulation. So, we generally recommend that a pacifier leash not exceed 7 – 8” as it is used so close to the neck and head. (An average 9 -12 month child has a neck circumference of between 8.3” – 10.7”.) Likewise, a toy tether should only be long enough to accomplish its intended use and no longer. You should probably look to competitor products and not exceed those lengths as there is likely a greater risk (based on the data above) of entanglement for every inch of material that you add. Generally, less than 12” is a length mentioned in Toy Standard (ASTM F963-11) Section 4.14 on Cords, Straps, and Elastics in Toys. You would need to review the specific details, such as loops and breakaway features, of that section yourself. (Unfortunately, it must be purchased as it is copyright protected.)

Lastly, you asked “Can the X manufacturer's lead testing certificates be used by registered Small Batch Manufacturers in place of lead testing?” – the answer to that is yes, provided the testing is current and up to date. Generally speaking, the testing must be no more than about a year old, otherwise it is no longer valid. Please see the sections on our website for component part testing and periodic testing for more information.