CEN TR 15371-2-2018 Safety of toys - Interpretations - Part 2 Replies to requests for interpretation of the chemical standards in the EN 71-series.pdf

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1、BSI Standards PublicationWB11885_BSI_StandardCovs_2013_AW.indd 1 15/05/2013 15:06Safety of toys - InterpretationsPart 2: Replies to requests for interpretation of the chemical standards in the EN 71-seriesPD CEN/TR 15371-2:2018National forewordThis Published Document is the UK implementation of CEN/

2、TR 15371-2:2018. It supersedes PD CEN/TR 15371-2:2017, which is withdrawn.The UK participation in its preparation was entrusted to Technical Committee CW/15, Safety of toys.A list of organizations represented on this committee can be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 pur

3、port to include all the necessary provisions of a contract. Users are responsible for its correct application. The British Standards Institution 2018 Published by BSI Standards Limited 2018ISBN 978 0 580 51734 1ICS 97.200.50Compliance with a British Standard cannot confer immunity from legal obligat

4、ions.This Published Document was published under the authority of the Standards Policy and Strategy Committee on 31 July 2018.Amendments/corrigenda issued since publicationDate Text affectedPUBLISHED DOCUMENTPD CEN/TR 15371-2:2018TECHNICAL REPORTRAPPORT TECHNIQUETECHNISCHER BERICHTCEN/TR 15371-2Augu

5、st 2018ICS 97.200.50 Supersedes CEN/TR 15371-2:2017EUROPEAN COMMITTEE FOR STANDARDIZATIONCOMIT EUROPEN DE NORMALISATIONEUROPISCHES KOMITEE FR NORMUNGCEN-CENELEC Management Centre: Avenue Marnix 17, B-1000 Brussels 2018 CEN Ref. No. CEN/TR 15371-2:2018: EAll rights of exploitation in any form and by

6、any means reserved worldwide for CEN national MembersSafety of toys - Interpretations - Part 2: Replies to requests for interpretation of the chemical standards in the EN 71-seriesScurit des jouets - Interprtations - Partie 2: Rponses aux demandes dinterprtation des normes chimie de la srie EN 71Sic

7、herheit von Spielzeug - Interpretationen - Teil 2: Antworten auf Anfragen zur Interpretation der chemischen Normen in der Normenreihe EN 71This Technical Report was approved by CEN on 9 April 2018. It has been drawn up by the Technical Committee CEN/TC 52.CEN members are the national standards bodie

8、s 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, Slovakia, Slove

9、nia, Spain, Sweden, Switzerland, Turkey and United Kingdom.English VersionCEN/TR 15371-2:2018 (E)European foreword iiiIntroduction iv0.1 Interpretations and no-action decisions . iv0.2 Requests for interpretation . iv0.3 Answers to requests for interpretations .v1 Scope . 62 EN 71-3:2013+A2:2017, Sa

10、fety of toys Part 3: Migration of certain elements 62.1 4.1 Toy material categories - “stickers” (interpretation): 62.2 4.1 Toy material categories - “erasers” (interpretation): . 62.3 4.1 Toy material categories (interpretation): . 73 EN 71-4:2013, Safety of toys Part 4: Experimental sets for chemi

11、stry and related activities 83.1 1 Combined chemical sets (interpretation): . 8iiContents PagePD CEN/TR 15371-2:2018CEN/TR 15371-2:2018 (E)European forewordThis document (CEN/TR 15371-2:2018) has been prepared by Technical Committee CEN/TC 52 “Safety of toys”, the secretariat of which is held by DS.

12、Attention is drawn to the possibility that some of the elements of this document may be the subject of patent rights. CEN shall not be held responsible for identifying any or all such patent rights.This document supersedes CEN/TR 15371-2:2017.In comparison with CEN/TR 15371-2:2017, one interpretatio

13、n sheet has been added.CEN/TR 15371 series, Safety of toys Interpretations, is currently composed of the following parts: Part 1: Replies to requests for interpretation of EN 711, EN 712, EN 718 and EN 7114; Part 2: Replies to requests for interpretation of the chemical standards in the EN 71 series

14、.iiiPD CEN/TR 15371-2:2018CEN/TR 15371-2:2018 (E)Introduction0.1 Interpretations and no-action decisionsThis 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

15、; EN 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 extractio

16、n; 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.The replies concern those requests that have resulted in an interpretation or a decision that no action is required

17、as the standard 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 interpre

18、tation should only 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.Disclai

19、mer: The interpretations 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

20、in the Official Journal of the European Union.0.2 Requests for interpretationRequests 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

21、agreed by CEN/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, t

22、aking into account:1) the wording of the standard;2) the rationale of the standard;ivPD CEN/TR 15371-2:2018CEN/TR 15371-2:2018 (E)3) the history of the standard.b) A noaction decision: This is applicable when it is agreed that the standard appropriately specifies how a toy shall be assessed.c) A pro

23、posal 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 15371-2, which will be updated on a regular basis.Proposals for amendments will be progressed as new work item p

24、roposals in accordance with CEN rules.0.3 Answers to requests for interpretationsSince 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 t

25、hemselves inform the originator of the request as appropriate.vPD CEN/TR 15371-2:2018CEN/TR 15371-2:2018 (E)1 ScopeThe 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; EN 7

26、1-4: 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; EN

27、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+A2:2017, Safety of toys Part 3: Migration of certain elements2.1 4.1 Toy material categories - “stickers” (

28、interpretation):Question The question relates to the categorization of “stickers” under EN 71-3:2013+A2:2017, 4.1 Toy material categories.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

29、/plastic falls 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 backi

30、ng).We would 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 a

31、lready placed 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

32、.REQ 001-13 (UNI, Italy)2.2 4.1 Toy material categories - “erasers” (interpretation):Question The question relates to the categorization of “erasers” under EN 71-3:2013+A2:2017, 4.1 Toy material categories.6 PD CEN/TR 15371-2:2018CEN/TR 15371-2:2018 (E)Erasers classified as toys which are made of po

33、lymeric material releases 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 (UN

34、I, Italy)2.3 4.1 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

35、 been given:If 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

36、removed. See example below:Figure 1It 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 hands of the user.Table 1 Cross-referen

37、ce table for determining categoryToy material Category I Category II Category IIICoatings of paints, varnishes, lacquers, printing inks, polymers, foams and similar coatingsX7PD CEN/TR 15371-2:2018CEN/TR 15371-2:2018 (E)Toy material Category I Category II Category IIIPolymeric and similar materials,

38、 including laminates, whether textile reinforced or not, but excluding other textilesXPaper and paper board XTextiles, whether natural or synthetic XGlass, ceramic, metallic materials XOther materials whether mass coloured or not (e.g. wood, fibre board, hard board, bone and leather)XCompressed pain

39、t tablets, materials intended to leave a trace or similar materials in solid form appearing as such in the toy (e.g. the cores of colouring pencils, chalk, crayons)X Pliable modelling materials, including modelling clays and plaster 3 X Liquid paints, including finger paints, varnishes, lacquers, li

40、quid ink in pens and similar materials in liquid form appearing as such in the toy (e.g. slimes, bubble solution)X Glue sticks X Reply It is recommended to use EN 71-3:2013+A2:2017, 4.1, Table 1, which categorizes the toy materials according to their application. If the toy material is a modelling m

41、aterial then 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)3 EN 71-4:2013, Safety of toys Part 4: Experimental sets for chemistry

42、 and related activities3.1 1 Combined chemical sets (interpretation):Question The EN 71-4 deals with 3 different types of sets in 3 different subclauses: 4.1 chemical sets 4.2 crystal growing sets 4.3 carbon dioxide generating setsIf a set is a combination of a chemical set, a crystal growing set an

43、d a carbon dioxide generating set would EN 71-4 be applicable and if yes what Subclauses should be assessed: EN 71-4:2013, 4.1 only, or EN 71-4:2013, 4.1, EN 71-4:2013, 4.2 and EN 71-4:2013, 4.3.Reply The standard EN 71-4:2013 does not cover such combined chemical sets for which the requirements are

44、 conflicting. Therefore, the standard cannot be used to demonstrate conformity with the requirements of the Directive 2009/48/EC in this respect. Therefore, we recommend to refer to article 19 of Directive 2009/48/EC (Applicable conformity assessment procedures).REQ 01-16 (NEN, NL)8 PD CEN/TR 15371-

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