Testing for the US market

The importance of testing and risk assessments to keep customers safe and minimise the risk of recalls.

by Mark Southam

Recent product recalls in the US have demonstrated the potential for injury (or even death) from footwear which has not been adequately – if at all – assessed for safety. For example, in early 2011, 57,000 children’s novelty slippers were recalled because it was possible to pull out the stuffing, posing a choking hazard to young children. Indeed, an incident had been reported in which a seven-month old child began to turn blue with the slipper’s stuffing in its mouth. In another product recall, several wearers received injuries, including broken bones and bruising, as a result of a style of sandal having poor slip resistance.

As well as the potentially large cost of losing the stock and the costs involved in administering product recalls, there could be damage to the reputation of the company or brand. There is even the risk of someone being seriously injured or killed – damages and associated court costs from product liability claims can be huge.

Suppliers of consumer goods (including footwear) in the US have a legal obligation to ensure that the product is safe for the user. Consumer product safety comes under the jurisdiction of an independent Federal agency, the Consumer Product Safety Commission (CPSC). Consumer products that violate the CPSC’s safety standards, bans, rules or regulations or otherwise present a substantial product hazard must not be sold.

The CPSC runs a number of initiatives, including the recently launched Product Safety Information Database. Consumers, child service providers, health care professionals, government officials and public safety entities can submit reports of injuries from consumer products. Manufacturers receive a copy of the report, and have the opportunity to comment. Reports and manufacturer comments are published online at www.saferproducts.gov for anyone to search.

Many consumer products are regulated and have specific laws defining their supply – toys and children’s products are an example. However, most everyday footwear falls into the unregulated category, and there is no specific legislation defining how everyday footwear should be assessed for safety. An exception here relates to requirements relating to restricted chemicals, which was discussed in the September 2010 issue of SATRA Bulletin.

It is the responsibility of suppliers to ensure that the footwear they sell is safe. Suppliers should protect customers from injuries, protect themselves from product recalls and potential product liability claims by screening products through risk assessment and testing procedures.

SATRA’s international reputation

In the absence of any legislative requirements, SATRA is able to help members to carry out this screening process. We have an international reputation for developing a vast range of testing procedures by which whole footwear, footwear materials and components can be assessed to ensure they are fit for purpose. These testing procedures go hand-in-hand with our extensive guideline recommendations, with which the results of test we carry out can be compared. SATRA’s footwear experience and extensive testing facilities mean that we are in the best position to be able to help our members in deciding what testing needs to be done.

Risk assessments are important, as not only will these highlight which safety critical tests are relevant to that particular product, but may also reveal hazards which might not be indicated by testing alone. For instance, assessing a children’s boot with pom-poms on the ends of cords might highlight the need for slip testing of the sole, strength of the pom-pom attachment and other such tests. A good risk assessment would also highlight the risk of the pom-poms on the left and right boots become entangled and tripping up the wearer – not a risk which would be shown up during normal testing. SATRA’s experience and knowledge means that we can help our members with risk assessments to look for potential hazards.

Every style is different, so SATRA can help to examine individual products to see where potential faults could give rise to a safety issue and recommend which tests we think are important. The key tests might include:

• Slip resistance
• Sole bond strength
• Heel attachment and heel strength (impact and fatigue resistance)
• Top-piece attachment
• Strap and fastening strength
• The presence of hazardous and restricted substances.

While we can help with initial testing at the pre-production stage, to ensure that products continue to comply throughout the production life, they should be regularly checked, perhaps for limited key properties. This could be done by submitting footwear from the warehouse or store. We can even purchase items from store on the company’s behalf.

Having staff who are able to examine their own products and to perform their own risk assessments is also important, and SATRA can also offer assistance in this regard. We offer a number of training courses which help staff members to better understand the product and to recognise hazards.

While many of our customers have their own testing laboratories, it is, however, essential that the test results the laboratory supplies are accurate and reliable. SATRA can carry out in-house laboratory accreditation for its members, which will play a key part in any company’s quality system. More details can be found at www.satra.co.uk

For information on SATRA's work in the USA, please visit www.satratechnology.com

Publishing Data

This article was originally published on page 38 of the June 2011 issue of SATRA Bulletin.

Other articles from this issue »

---