Product safety standards
Issues
- There is a number of consumer safety standards which are about to be revoked because of a lack of funding. How / whether to continue supporting them, with funding from alternative source(s) needs urgent attention.
- The role of international standards in determining New Zealand infant products safety should be examined to see whether they could offer a suitable / less costly substitute to New Zealand developed standards (which are, in any case, based heavily on international standards).
- There seems to be a confusing proliferation of standards marks and labels.
- The benefits of horizontal standards for infant products may outweigh the duplication of effort involved in creating safety standards for each product.
- Standards development and amendment seems to take too long, and is prioritised regardless of the relevant injury data.
- Standards development must have regard for both safe usage and common usage.
- User education must be an integral part of standards development. For example, requiring safety harnesses for prams and pushchairs must recognise a need to educate consumers into using them.
- Standards may lose their effectiveness as products age and change ownership.
- Effective voluntary standards require a strong, committed industry.
- A product that meets a standard (either mandatory or voluntary) is still not necessarily a safe product. This is because the coverage of a standard may not encompass all product uses and eventualities.
Discussion
New Zealand standards are based on international standards. When considering their application in this country, they have been either adopted unchanged or, by a process of consultation, changed to make them appropriate to New Zealand conditions.
There is current discussion over how (or whether) Standards New Zealand's (SNZ) ongoing support for a number of consumer safety standards can be funded from other sources, as SNZ is no longer able to fund their development from within its own resources. The Ministry is looking at ways alternative sources of funding can be obtained, especially through the infant products industry as a current beneficiary of the existing standards. In the event that a number of current standards are revoked or allowed to lapse, the options for safety agencies such as the Ministry include drawing on appropriate international standards in recommending mandatory standards for Ministerial approval, or in determining whether infant products are unsafe.
Product safety (mandatory) standards are relatively costly to make and to enforce. These costs are then met, as a cross-subsidy, by the taxpayer rather than by the purchaser of the product. Mandatory standards are only recommended by the Minister, for approval by the Governor-General in Council, after consultation with all those who are substantially affected by the proposal. This process can take many months.
There are often cheaper and more effective options to mandatory standards available - for example by industry agreeing to comply with a standard, or through a consumer education campaign. For these reasons the Ministry has looked upon mandatory standards as a last resort - to be used only if other action would be ineffective or inappropriate and then only if it would actually solve a safety problem. A more detailed explanation of the Ministry's policy on mandatory standards is contained in the Ministry's Policy Paper No 2, Mandatory and Voluntary Product Standards.
Suggestions for Action
- Identify critical consumer safety standards and secure funding for their continued development and maintenance from sources outside of SNZ.
- Strengthen the existing industry grouping (the Infant Products Association) and seek its agreement to pursue industry commitment to enforceable safety standards.
- Address current and emerging standards in the context of second-hand products and the life expectancy of products.
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These suggestions for action are reflected in the
"agenda for action". Is there anything that should be
added?
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