Infant Products Safety
Appendix Three
INFANT PRODUCTS SAFETY
Keith Manch, Ministry of Consumer Affairs - Overview and Key Issues

Bob Ainsworth, New Zealand Juice Association

Dr David Chalmers - Injury Prevention Unit, University of Otago

Professor Joan Ozanne-Smith - Monash University Accident Research Centre

Dr Kaye McAulay - Chief Executive Standards New Zealand

Rachel Leamy - Commerce Commission

Dennis Chan - Infant Products Association

John Highsted, Britax Child-Care Products Pty - a manufacturer's point of view

Shelley Hanifan, Safekids - Child Safety Service of Starship Hospital

Druis Barrett - Maori Women's Welfare League

Tafa Poutoa, Pacifica - A Pacific Islands Perspective

Pacific Islands consumers are unlikely to return a product to the retailer. From Pacific Islands perspective it is the responsibility of the retailer to demonstrate the safe use of a product.

Sue Campbell National Child Safety Co-ordinator for Plunket


CONTENTS

FOREWORD

EXECUTIVE SUMMARY

AN AGENDA FOR ACTION

DISCUSSION PAPER, THE MINISTRY, AND THE FORUM

ISSUES, DISCUSSION AND SUGGESTIONS FOR ACTION

APPENDIX 1

APPENDIX 2

PRESENTATIONS MADE TO THE INFANT PRODUCTS SAFETY FORUM ON MONDAY 6 OCTOBER 1997.

(NOTE: A copy of the full papers presented is available from the Ministry of Consumer Affairs, PO Box 1473, Wellington).

Keith Manch, Ministry of Consumer Affairs - Overview and Key Issues

A goal for the Ministry was 'Safe Products, Safe Use for New Zealand Consumers'. Achieving this depended on an integrated strategy. It involved:

  • Partnership - an acknowledgment that all have a part to play in improving the safety of infant products

  • Government Involvement - a role as catalyst and facilitator with proactive monitoring of the market, complaints investigations, developing certain standards, networking nationally and internationally, educating and informing traders and consumers, developing policy, and encouraging self-regulation

  • Standards - the use of mandatory standards where they are seen as the best approach to achieving safety

    • Education - the distribution of material and the use of programmes and campaigns on specific areas of consumer safety

    • Information - the collection of data about injuries, product information and compliance strategies

    • Self-regulation - the establishment of codes of practice, monitoring and compliance frameworks administered by the relevant industries.

Bob Ainsworth, New Zealand Juice Association

Formed in 1994.
Covers Fruit Juice and Fruit Drink Beverage companies.
Major concern was adulteration of product (added sugar, concentrate, pulpwash).
Growing factors, extraction and processing techniques, and legislation affect quality and authenticity of product.

Voluntary Code of Practice working with Food Regulations:

  • has infrastructure

  • has policing and sanctions

  • has public message

  • is flexible and cost efficient

  • promotes fair practice.

Principles of fair practice:

  • creativity stops where adulteration begins

  • manipulations harm is the industry and consumer.

Self Regulation through Industry Compliance Committee (ICC).

Breaches of Code:

  • first breach - warning and further testing

  • subsequent breach/es - publish test results, advise government enforcement agencies, institute proceedings for damages.

Benefits of Self-Regulation:

  • good and healthy image for the industry

  • minimises government involvement

  • ensures free and fair competition

  • gains internationally recognised standards

  • increases sales volume.

Dr David Chalmers - Injury Prevention Unit, University of Otago

35 infant product related deaths in NZ in the period 1985-1994.

  • 94% of deaths comprised of children aged between 0 and 2.

  • Stationary cots and portable cots were responsible for 68% and bunk beds were responsible for 20% of infant product related deaths.

  • 71% of infant product related deaths were as a result of suffocation and respiratory obstruction. 11% resulted from the infant being caught in or between an object.

2000 infant product related hospitalisations 1985-1994.

    46% of infant product related hospitalisations involved infants between 0 and 2.

  • 31% of those hospitalisations resulted from use of bunk beds, 7% from cots or portable cots and 37% from beds.

  • 92% of infant product related hospitalisations were as a result of the infant suffering a fall. Of those falls 36% were from beds, 33% were from bunk beds.

  • 43% of hospitalisations involved infants suffering head injuries, 36% of injuries related to fractured limbs and 8% of injuries involved a fractured skull.

Professor Joan Ozanne-Smith - Monash University Accident Research Centre

Injury Data:

  • Most common nursery furniture products associated with infant injuries are prams, cots, high chairs, baby walkers, strollers, change tables and bouncinettes

  • Injuries associated with nursery furniture are most likely to occur in the first year of life

  • Over 3,500 nursery furniture injuries are suffered by infants aged under 1 year

  • Of 13 deaths between 1985-1994, over 75% of those occurred from use of cots

  • Falls are the major cause of non-fatal injury.

Major Hazards:

  • Cots - entrapment , modifications, protrusions

  • Bouncinettes - falls

  • Babywalkers - falls involving steps and stairs

  • High chairs - inadequate restraints to prevent falls

  • Prams and Stroller - falls, entrapment asphyxiation, deficient safety harnesses or lack of use, overloading strollers with shopping

  • Change tables - lack of restraining devices to prevent falls.

Key Recommendations:

  • Mandating of cot standard

  • Voluntary standards for baby walkers, high chairs and change tables

  • Increase compliance with voluntary standards via industry co-operation and public education

  • Mandating where voluntary standards are ineffective

  • Improved hospital data collection

  • Point-of-sale information about the correct use of products and the associated hazards for parents and caregivers

  • Community service television advertisements to support interventions.

Dr Kaye McAulay - Chief Executive Standards New Zealand

Standards NZ is the trading arm of the Standards Council. Its functions include:

  • developing standards and standards related publications
  • assessing products and certifying products for conformance to a particular standard
  • providing information services on standards
  • NZ's representative in the ISO and various other international standards organisations

Standards are used as:

  • a means of achieving safety and reliability of products

  • technical means of complying with regulations

  • guidance on good practice.

Making use of standards in infant safety area:

  • provides manufacturer design requirements for preventing accidents

  • provides regulators with a practical method for defining minimum requirements

  • provides consumers with a benchmark for purchasing decisions
  • can be used with confidence as they have all been developed at the request of the community using public consultation processes and input from a wide range of interested groups.

Rachel Leamy - Commerce Commission

Role to bring about awareness, acceptance of and compliance with the Commerce Act and the Fair Trading Act, carried out via:

  • information provision, including guidelines on each of the product safety standards

  • complaint handling

  • enforcement

  • court action.

Enforcement of Product Safety Standards:

  • product safety issues identified via complaints from public or competitors, information from other government agencies such as MCA or Customs Dept, or from pro-active inspection programme which Commission operates

  • use of investigation criteria, for example size and spread of consumer loss, repeated breaches of Act by traders, or need to clarify the law or provide a deterrent

  • if there appears to be a prima facie breach of a mandatory product safety standard the Commission will investigate the matter

  • if an investigation establishes an apparent prima facie breach the Commission will take action in the form of a warning, obtain a settlement, negotiate a voluntary recall or take court action

Mandatory standards do not guarantee safe products because:

  • non-complying goods are still sold

  • not all potential hazards are covered by the standard

  • standards only apply up to when the goods are purchased, not to modifications of the product or when warnings are not followed.

Dennis Chan - Infant Products Association

Mission Statement:

  • aim to advance the interests of the juvenile products industry

  • encourage use of its products

  • collect and disseminate information

  • promote safety awareness and voluntary standards

  • project a positive image to the industry to the public.

John Highsted, Britax Child-Care Products Pty - a manufacturer's point of view

Factors which enable the manufacturer to deliver safe products include:

  • knowledge of injury avoidance and familiarity with the product

  • design guidelines and minimum standard levels to support the designer and provide a means of evaluating a product, particularly as most children's products are imported

  • a quality system e.g. Certification

  • maintenance of quality to ensure all products meet the minimal level of safety

Britax has sought testing for all of its product to ensure compliance and product safety.
Some Australian and NZ companies import or manufacture without testing to determine the level of safety of their products.

Britax recommends a mandatory standard for all popular children's products, similar to the Toy Standard:

  • requiring all products meet minimum safety standards. Low cost products not meeting standard would not be permitted, and any injuries would lead to further improvement of the standard

  • cover all manufacturers and importers

  • must be one standard appropriate to the identified risks not just taking on the CEN standard or acceptance of non-equivalent standards - which leads to confusion.

Shelley Hanifan, Safekids - Child Safety Service of Starship Hospital

The Spectrum of Prevention - A Framework for Planning Outlines a continuum of strategies which create a potent recipe for prevention work in childhood injury.

Strategies:

  • Information - What's going on, Who's doing what, and How to information, research into injury patterns and risk factors

  • Building Coalitions and Networks - sharing information and combining efforts to create more effective prevention interventions

  • Strengthen Individual Knowledge and Skills - provide practical assistance to caregivers in the form of counseling education or knowledge

  • Educate the Community - to raise awareness about child injury issues, change public attitudes or provide prevention information

  • Educate Existing (and Potential) Providers

  • Change Organisational Practices to an increased emphasis on child injury prevention

  • Influence Public Policy and Legislation.

Approaches to the issue of infant products:

  • Gather information on the product in question, seeking information from overseas about their experience, opinion from those involved in implementation of safety controls, and soft data including opinions and preferences

  • Use networks to share information and raise awareness on the issue

  • develop strategies to improve the safety of the product

  • educate parents and families on an individual level

  • community education

  • educating people who sell the product to parents

  • raise awareness within the industry and encourage action to improve or ensure the safety of the product

  • approach government agencies to request appropriate intervention

Druis Barrett - Maori Women's Welfare League

Main objective to support Maori women and their whanau. Infant product safety is a holistic issue for Maori.

Toys, cots, and highchairs are usually a luxury rather than a norm.

  • Maori usually purchase second hand equipment if any at all

  • a high proportion of Maori women are sole parent families and cannot afford safety products for their children.

Safety issues are not a priority with most whanau. This is mainly because of their living standards, the location of Maori mothers and distance costs.

We need to ask where Maori women are placed economically in view of safety standards.

Tafa Poutoa, Pacifica - A Pacific Islands Perspective

Tafa Poutoa emphasised the need for instructions to have graphics to reach Pacific Islands consumers as:

  • Pacific Islands consumers do not access information through printed form

  • practical demonstration is the most effective way of providing information to Pacific Islands consumers.

Pacific Islands consumers are unlikely to return a product to the retailer. From Pacific Islands perspective it is the responsibility of the retailer to demonstrate the safe use of a product.

Sue Campbell National Child Safety Co-ordinator for Plunket

Plunket is a leading child health provider and is well placed to deliver child safety information to the public. It has an active advocacy role in child safety issues.

Plunket believes nursery products should come under mandatory standards as:

  • self regulating by manufacturers and importers is not working

  • there is no incentive for manufacturers and importers to certify to the voluntary product standard

  • the cost of standard certification is taking priority over child safety

    this ensures optimum safety and public confidence in product safety

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