Modern Testing Services CPSIA Certification and Testing Program

Modern Testing Services CPSIA Certification and Testing Program for Children’s Product & Non-Children’s Product YOUR QUALITY ASSURANCE SOLUTION

Summary Chart of Requirements for Children’s and Non Children’s Products Children’s products Non-children’s products Certification Testing Production Testing Plans Suggested Material Change Tracking Representative Sampling Records of Undue Influence Corrective Actions Product Specifications Suggested Documentation Storage 2

Children’s Product Certification • All children’s products require 3 rd party testing at CPSC approved accredited test lab for all applicable requirements • Written certification for each children's product must be based upon passing test results obtained from the required third party testing at a CPSC accepted laboratory. • Final Rule of Children’s Product Testing & Certification 16 CFR 1107 Effective date of Children’s Product Certification Program: Feb 13, 2013 3

The following children’s products or applicable rules, bans, and standards require a certification program: • • • Baby walkers Children’s ATVs Children’s bike helmets Children’s bunk beds Children’s carpets and rugs Children’s clothing Children’s mattresses/pads Children’s metal jewelry Children’s vinyl plastic films Cribs Dive sticks • • • Infant walkers Infant rattles Pacifiers Toys Caps and toy guns Children’s sleepwear Durable infant products Lead in surface coatings Lead in substrates Small parts ASTM F 963 Phthalates 4

The following general use products require certification per a Reasonable Testing Program: Adult apparel • Adult bikes • Adult bunk beds • Adult carpets • Adult vinyl plastic film • Architectural glazing • Candles (metal wicks) • CB antennas • Cellulose insulation • Child-resistance on portable gas • containers Cigarette lighters • • Contact adhesives • • Fireworks • • • Garage door openers Lawn mowers Matchbooks Multi-purpose lighters Adult ATV’s General use furniture (coatings) Adult mattresses Paint Refrigeration door latches Special packaging under PPPA Swimming pool slides Unstable refuse bins 5

Periodic Testing Plan • All manufacturers must conduct Periodic Testing by third party conformity assessment body to ensure compliance. – Test Interval of Periodic Testing (either one of below: ) § At least once a year § At least once every two years (if manufacturers have a production testing plan) § At least once every three years (if manufacturers conducting testing to ensure continued compliance with the applicable children’s product safety rules using a testing laboratory accredited to ISO/IEC 17025: 2005, and test to the same test 6 methods required in certification testing)

Periodic Testing Plan (cont’) • Factors to be considered for testing interval included but not limited to: – High variability in test results – Result close to the limit (eg. Marginal result) – Manufacturing process factors that could affect the compliance – Consumer complaints or warranty claims – New components part added – Potential cause injury or death from noncompliant – High volume products manufactured or distributed widely in US – Visually undetectable non-compliance 7

Periodic Testing Plan (Cont’) • Production Test Plan – Production management techniques and tests to provide a high degree of assurance that products manufactured after certification. – Use of Process Management Techniques § Control charts, § Statistical process control programs § Failure Modes and Effects Analyses (FMEAs) § Nondestructive and tailored measurement § Testing by documented testing methods 8

Periodic Testing Plan (Cont’) • Production Test Plan included below elements: – Description of the production test plan included: § § § Description of the process management techniques Test to be conducted Measurements to be taken Intervals of tests or measurement taken Number of samples tested – Specific production test plan for each manufacturing site. – The production testing intervals should be appropriate to provide a high degree of assurance. 9

Material Change • Any changes of material in product design, or manufacturing process, including the sourcing of components parts, is required for new certification testing 10

Representative Sampling: • Samples tested for periodic testing must be representative of the production lot produced in the period. • A sufficient number of representative samples must also be selected to support that inference. • Documentation of how the samples were chosen and evidence of those samples (i. e. , the date they were selected and testing results) must be maintained for the records. 11

Undue Influence • Manufacturer must establish procedures to safeguard against the exercise of undue influence on a third party conformity assessment body including: – Written policy statement – Staff Training with signing a statement attesting to participation – Notification to CPSC immediately – Any undue influence may be reported confidentially to the CPSC 12

Corrective Action Plan • Product are tested with FAIL test results with respect to any CPSC enforced specification, rule, law or standard. • The Corrective action plan should clearly identify the steps should be taken by the manufacturer to investigate and remedy failure including: – The changes of manufacturing process or equipment – The changes products design and/or materials – Other actions taken to ensure compliance ** Any changes of material in product design, or manufacturing process, including the sourcing of components parts, is required for new certification testing** 13

Record Keeping • Manufacturers must maintain the following records in English (or by other language that translated into English accurately within 48 hrs) for 5 years either in hardcopy or electronically upon CPSC requested for inspection. – Children’s Product Certificate (CPC) – Test Reports for Certification – Periodic testing (either one of below: ) § Periodic test plan + Periodic Test Results; § Production test plan + Production Test Results + Periodic Test Results; § Testing Results by ISO/IEC 17025: 2005 accredited inhouse lab. + Periodic Test Results. – Records of any material change, manufacturing process, sourcing of component parts in a product – Records of undue influence procedures and training – Corrective Action Plan & corrective actions taken 14

Summary for Children Certification Program Manufacturers 3 rd Party Testing Initial Product Certification Children Product Certificate Continued Production Re-certification for material change Undue Influence Policy & Training Periodic Testing Either 1 of below options Periodic Testing Plan Production Testing Plan Continued Testing by ISO 17025 accredited lab. At least 1 per year At least 1 per 2 years At least 1 per 3 years All document and records shall be kept for 5 years High Degree of Assurance 15

Option 2 Manufacturer with Production Testing Plan Undue Influence Policy & Training Record 3 rd Party Testing Certification Testing Result Periodic Testing Result Product Development Product Specification Procurement Sourcing Information Raw Materials Incoming Material Quality Control (IQC) Raw Material Ware House Pre-Production Mass-Production Product Warehouse CPC Process Flow Document/Data Flow Continued Production Raw Material / Semi. Product / Finished Product drawn for testing Buyer Requirement Production Testing Plan Production Test Result Corrective Action If necessary Record Keeping by Document Management System 16

Testing Plan Comparison Items Option 1 Option 2 Option 3 Frequency of Periodic Testing At least 1 per year At least 1 per 2 years At least 1 per 3 years Cost of Periodic Testing High Medium Low Production Testing Plan Not Applicable Implemented Cost of Production Testing Not Applicable Low Cost of Inhouse lab. investment Not Applicable Medium (alternative test method allowed) Suitability – manufacturer size Small (no inhouse lab. ) Medium with inhouse lab. Large with ISO 17025 accredited inhouse lab. Variety of Product Type Low High Based on 1. Quality Management syste Medium 2. Product Risk 3. Manufacturing process va High (method must same as 3 rd Party testing) 17

Business opportunity we have? • Develop the product specification for supplier • Representative sampling – on-site pickup sample directly • Gap analysis in factory to meet the option 2 [USD 850/manday] • Quality management system consultant service. i. e help to renew/create the Quality manual • Provide a Document storage Platform 18

Reference Materials: Items Website Final Rule of Testing and Labeling Pertaining to Product Certification, (November 8, 2011) http: //www. cpsc. gov/businfo/frnotices/fr 12/c ertrepr. pdf Sample children's product certificates (CPC) http: //www. cpsc. gov/businfo/cpc. html Final Rule of Conditions and Requirements for Relying on Component Part Testing or Certification, or Another Party's Finished Product Testing or Certification, to Meet Testing and Certification Requirements (November 8, 2011) http: //www. cpsc. gov/businfo/frnotices/fr 12/t estrelyfinal. pdf FAQs of Certification and Third Party Testing http: //www. cpsc. gov/info/toysafety/3 ptfaq. ht ml Information on Testing and Reasonable Testing http: //www. cpsc. gov/businfo/generaluse. html Programs Information on General Certificate of Conformity (GCC) http: //www. cpsc. gov/businfo/gcc. html FAQs of Certification and Testing for General Use, or Non-Children's, Products http: //www. cpsc. gov/businfo/generalusefaq. h tml 19

Pro. Compliance MTS Share Point for Reasonable Test Program

Pro. Compliance Sharing Logic: Facebook Connection 21

Pro. Compliance C 1 Faber. Castell (C 1) ABC Company (VA) P 1, P 2 HEB (C 2) P 1 CCC Production (VB) FCC Company (VC) C 2 C 3 Costco(C 3) Ax P 2 Ay P 3, P 4 P 5, P 6 VA P 1 VB P 2 P 3 VC P 4 P 5 P 6 22

Pro. Compliance is a solution in compliance with a number of regulations such as EU and US, a user-friendly, web-based artificial intelligence application to store all the product information e. g. technical files/reports …. etc. 23

Pro. Compliance A user-friendly Interface: 24

Pro. Compliance Product page pop-up after searching. Vendor of this product could post technical documents to the database for storage. Buyer of this product could browse the stored documents through this page. 25

Pro. Compliance Example 1: Holiday Times (VB) 26

Pro. Compliance Example 2: The Children’s Place (C 3) 27

Pro. Compliance Next Phase: Component sharing Sky Helicopter (P 1) � � Landing Helicopter (P 2) Toy Car (P 3) P 1 P 2 P 3 � � � 28

Pro. Compliance – Vendor’s Application Form Submitted by Vendor. Create Login Account for Vendor. Save the Record in Database. Create Document Storage Folder for Each Product. Provide Vendor with Login Information and User Manual of Pro. Compliance Training Session may be Provided on Request. 29

Pro. Compliance – Available Function for Vendor Upload documents Download Documents Search Pro. Compliance Landing Page Check if any documents missing View All Products Check Available Products Individual Download All at once Show no. of Documents Downloaded Show Document versions with dates 30

Pro. Compliance – Buyer’s Application Marketing Staff Received Application from Buyer. Create Login Account for Buyer. Save the Record in Database Provide Buyer with Login Information and User Manual of Pro. Compliance MTS will create the relationship diagram between Buyer and Vendor Training Session may be Provided on Request. 31

Pro. Compliance – Available Function for Buyer Download Documents Search Check if any documents missing Pro. Compliance Landing Page View All Products Check Available Products Individual Download All at once Show no. of Documents Downloaded Show Document versions with dates 32

Pro. Compliance – MTS Administration Role Upload Documents Search Pro. Compliance Landing Page Download Documents Check if any documents missing MTS Test Reports ONLY Individual Download All at once Show no. of Documents Downloaded Show Document versions with dates View All Products Check Available Products Create User ID for Clients Record Clients’ Service Validity in Database Monitor the Expiry Date Alert Client 1 Month before Expired Create Product Page Grant Access Right to specific Client Keep Access Right Record in Database Monitor the correctness of Access Right 33

Case Demo HEB TRU Michaels Vendor A Item 1, Item 2 -- Vendor B -- Item 3, Item 4 Vendor C Item 5 -- Item 5, Item 6 34

YOUR QUALITY ASSURANCE SOLUTIONS

Testing Q & A Section Auditing Inspection YOUR QUALITY ASSURANCE SOLUTION 36