CEN/TR 16411:2014
(Main)Child use and care articles - 2014 compiled interpretations of CEN/TC 252 standards
Child use and care articles - 2014 compiled interpretations of CEN/TC 252 standards
The purpose of this Technical Report is to provide replies to requests for interpretations and clarifications of:
- EN 1273:2005, Child use and care articles - Baby walking frames - Safety requirements and test methods;
- EN 1888:2012, Child care articles - Wheeled child conveyances - Safety requirements and test methods;
- EN 1930:2011, Child use and care articles - Safety barriers - Safety requirements and test methods;
- EN 12586:2007, Child use and care articles - Soother holder - Safety requirements and test methods;
- EN 12790:2009, Child use and care articles - Reclined cradles;
- EN 12221-1:2008, Changing units for domestic use - Part 1: Safety requirements;
- EN 12221-2:2008, Changing units for domestic use - Part 2: Test methods;
- EN 1466:2004+A1:2007, Child care articles - Carry cots and stands - Safety requirements and test methods;
- EN 14350-2:2004, Child use and care articles - Drinking equipment - Part 2: Chemical requirements and tests;
- EN 1400-3:2002, Child use and care articles - Soothers for babies and young children - Part 3: Chemical requirements and tests;
- EN 1400:2013+A1:2014 Child use and care articles - Soothers for babies and young children;
- EN 14372:2004, Child use and care articles - Cutlery and feeding utensils - Safety requirements and tests;
- EN 12586:2007, Child use and care articles - Soother holder - Safety requirements and test methods;
- CEN/TR 16411:2012, Child use and care articles - 2012 compiled interpretations of CEN/TC 252 standards
Articles de puériculture - Compilation des interprétations des normes du CEN/TC 252 en 2014
Izdelki za otroke - Leta 2014 zbrane interpretacije standardov CEN/TC 252
Namen tega tehničnega poročila je zagotoviti odgovore na zahteve za razlago in pojasnilo naslednjih standardov:
– EN 1273:2005, Izdelki za otroke – Hojce – Varnostne zahteve in preskusne metode;
– EN 1888:2012, Izdelki za otroke – Otroški vozički – Varnostne zahteve in preskusne metode;
– EN 1930:2011, Izdelki za otroke – Varnostne pregrade – Varnostne zahteve in preskusne metode;
– EN 12586:2007, Izdelki za otroke – Držalo dude – Varnostne zahteve in preskusne metode;
– EN 12790:2009, Izdelki za otroke – Sklopne zibelke
– EN 12221-1:2008, Previjalne mize za domačo uporabo – 1. del: Varnostne zahteve;
– EN 12221-2:2008, Previjalne mize za domačo uporabo – 2. del: Preskusne metode
– EN 1466:2004+A1:2007, Izdelki za otroke – Prenosne posteljice in podstavki – Varnostne zahteve in preskusne metode;
– EN 14350-2:2004, Izdelki za otroke – Pripomočki za pitje – 2. del: Kemijske zahteve in preskusi
– EN 1400-3:2002, Izdelki za otroke – Dude za dojenčke in malčke – 3. del: Kemijske zahteve in preskusi
– EN 1400:2013+A1:2014, Izdelki za otroke – Dude za dojenčke in malčke;
– EN 14372:2004, Izdelki za otroke – Jedilni pribor in posoda za hranjenje – Varnostne zahteve in preskusi;
– EN 12586:2007, Izdelki za otroke – Držalo dude – Varnostne zahteve in preskusne metode;
– CEN/TR 16411:2012, Izdelki za otroke – Leta 2012 zbrane interpretacije in razlaga standardov CEN/TC 252
General Information
Relations
Standards Content (Sample)
SLOVENSKI STANDARD
SIST-TP CEN/TR 16411:2015
01-marec-2015
1DGRPHãþD
SIST-TP CEN/TR 16411:2014
Izdelki za otroke - Leta 2014 zbrane interpretacije standardov CEN/TC 252
Child use and care articles - 2014 compiled interpretations of CEN/TC 252 standards
Articles de puériculture - Compilation des interprétations des normes du CEN/TC 252 en
2013
Ta slovenski standard je istoveten z: CEN/TR 16411:2014
ICS:
97.190 Otroška oprema Equipment for children
SIST-TP CEN/TR 16411:2015 en,fr,de
2003-01.Slovenski inštitut za standardizacijo. Razmnoževanje celote ali delov tega standarda ni dovoljeno.
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TECHNICAL REPORT
CEN/TR 16411
RAPPORT TECHNIQUE
TECHNISCHER BERICHT
December 2014
ICS 97.190 Supersedes CEN/TR 16411:2014
English Version
Child use and care articles - 2014 compiled interpretations of
CEN/TC 252 standards
Articles de puériculture - Compilation des interprétations
des normes du CEN/TC 252 en 2014
This Technical Report was approved by CEN on 25 November 2014. It has been drawn up by the Technical Committee CEN/TC 252.
CEN members are the national standards bodies 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, Slovakia, Slovenia, Spain, Sweden, Switzerland, Turkey and United
Kingdom.
EUROPEAN COMMITTEE FOR STANDARDIZATION
COMITÉ EUROPÉEN DE NORMALISATION
EUROPÄISCHES KOMITEE FÜR NORMUNG
CEN-CENELEC Management Centre: Avenue Marnix 17, B-1000 Brussels
© 2014 CEN All rights of exploitation in any form and by any means reserved Ref. No. CEN/TR 16411:2014 E
worldwide for CEN national Members.
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Contents Page
Foreword .3
Introduction .4
1 Scope .7
2 00252033 – EN 1273:2005, Child use and care articles — Baby walking frames — Safety
requirements and test methods .8
3 00252059 – EN 1888:2012, Child care articles — Wheeled child conveyances — Safety
requirements and test methods . 10
4 00252051 - EN 1930:2011, Child use and care articles — Safety barriers — Safety
requirements and test methods . 13
5 00252046 - EN 12586:2007, Child use and care articles – Soother holder – Safety
requirements and test methods . 14
6 00252048 - EN 12790:2009, Child use and care articles — Reclined cradles . 24
7 00252049 - EN 12221-1:2008 , Changing units for domestic use — Part 1: Safety
requirements . 25
8 00252050 - EN 12221-2:2008, Changing units for domestic use — Part 2: Test methods . 28
9 00252054 - EN 1466:2004+A1:2007, Child care articles — Carry cots and stands — Safety
requirements and test methods . 29
10 00252032 - EN 14350-2:2004, Child use and care articles — Drinking equipment — Part 2:
Chemical requirements and tests . 32
11 00252089 - EN 1400:2013+A1:2014, Child use and care articles - Soothers for babies and
young children - Safety requirements and test methods . 33
12 00252024 - EN 14372:2004, Child use and care articles — Cutlery and feeding utensils —
Safety requirements and tests . 40
13 EN 16120:2012, Child use and care articles - Chair mounted seat . 41
14 00252067 – CEN/TR 16411:2012, Child use and care articles - 2012 compiled
interpretations of CEN/TC 252 standards . 43
Annex A (informative) Interpretation 3 on 3.9 and 5.1.4.2 in EN 12586:2007, Child use and care
articles — Soother holder — Safety requirements and test methods (WI 00252046) . 45
A.1 Introduction . 45
A.2 Examples of possible ventilation holes in more recent models of soother holders . 46
Annex B (informative) Reply to interpretation 3 on 3.9 and 5.1.4.2 in EN 12586:2007, Child use
and care articles — Soother holder — Safety requirements and test methods (WI
00252046) . 48
Annex C (informative) Reply to interpretation 1 on 5.1.10 in EN 12586:2007 Child use and care
articles — Soother holder — Safety requirements and test methods (WI 00252046) . 50
C.1 Ventilation holes in fastener (5.1.10) . 50
C.2 Discussion . 50
C.3 Final Interpretation . 55
Bibliography . 56
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Foreword
This document (CEN/TR 16411:2014) has been prepared by Technical Committee CEN/TC 252 “Child use
and care articles”, the secretariat of which is held by AFNOR.
Attention is drawn to the possibility that some of the elements of this document may be the subject of patent
rights. CEN [and/or CENELEC] shall not be held responsible for identifying any or all such patent rights.
This document supersedes CEN/TR 16411:2014.
The list below shows the requests for clarification/interpretation approved since 2013 plenary meeting:
N° Standard Title Subject Doc N°
Ventilation holes for clips
1 EN 12586:2007 Soother holder (safety and test) N 1228
(5.1.4.2 (B.11) 6.1.9.2
(Figures 16 and 17)
Baby walking frames – Safety
2 EN 1273:2005 6.6.2.3 “tip over test” N 1266
requirements and test methods
8.1.2 “removal of the child:
3 EN 16120:2012 Chair mounted seat case of unintentional locking N 1219
device”
4.5.3 ” The protected volume
for pram body”,
6 “consideration of phthalates”
Wheeled child conveyances –
4 EN 1888:2012 Safety requirements and test N 1215
8.4 ” connection point of the
methods
cord/string/narrow fabric and
location of the connection”
8.9.1.2.1 “brakes”
Clause 8 “Clarify of the text” in
5 EN 14350:2002 Drinking equipment N 1194
Product information
EN 1400:2013+A1: Soothers for babies and young Clause 6”Clarify of the text” in
6 N 1194
2014 children Product information
CEN/TR 16411:201 2012 compiled interpretations of
7 5.1.4.2 “ventilation holes” N°1262
2 CEN/TC 252 standards
Soother holder - Safety
8 EN 12586:2007 5.1.4.2 “ventilation holes” N°1262
requirements and test methods
EN 1400:2013+A1: Soothers for babies and young
9 8.3 “axis of shield” 1255
2014 children
EN 1400:2013+A1: Soothers for babies and young Various requests on the use
10
2014 children of “should”
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Introduction
This Technical Report contains replies to requests for interpretation and clarifications with regard to the
understanding of clauses in the standards elaborated within the CEN/TC 252. The replies concern those
requests which have resulted in an interpretation or the decision that no action is necessary.
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 interpretation will only be regarded as a clarification of the meaning of the
standard.
a) Disclaimer:
The interpretations and clarifications have been derived by expert groups of CEN/TC 252. 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 in
the Official Journal of the European Union.
b) Requests for interpretation:
Requests for interpretations may be submitted by a CEN member body through its national committee or by a
CEN/TC 252 liaison (but not directly by an individual or a company) - in accordance with the interpretation
protocols agreed by CEN/TC 252. The requests are then channelled to the relevant CEN/TC 252 working
group which will deal with the request.
A request for an interpretation may lead to:
1) an interpretation of the standard:
this should reflect a reasonable interpretation of how the standard should be used, while taking into
account:
i) the wording of the standard;
ii) the rationale of the standard;
iii) the history of the standard;
2) a no-action decision:
this is applicable when it is agreed that the standard appropriately specifies how a child care article
should be assessed;
3) a proposal for an amendment of the standard:
this is applicable when it is agreed that the standard is deficient in some way.
NOTE Interpretations are published in CEN/TR 16411, which will be updated on a regular basis.
Proposals for amendments will be progressed as new work item proposals in accordance with CEN rules.
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c) Answers to requests for interpretations:
Since requests for interpretations are submitted through a CEN member body, it is assumed that the member
body will keep itself informed about decisions concerning the request and its progress and will itself inform the
originator of the request as appropriate.
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1 Scope
The purpose of this CEN Technical Report is to provide replies to requests for interpretations and clarifications
of:
— EN 1273:2005, Child use and care articles — Baby walking frames — Safety requirements and test
methods;
— EN 1888:2012, Child care articles — Wheeled child conveyances — Safety requirements and test
methods;
— EN 1930:2011, Child use and care articles — Safety barriers — Safety requirements and test methods;
— EN 12586:2007, Child use and care articles — Soother holder — Safety requirements and test methods;
— EN 12790:2009, Child use and care articles — Reclined cradles;
— EN 12221-1:2008, Changing units for domestic use — Part 1: Safety requirements;
— EN 12221-2:2008, Changing units for domestic use — Part 2: Test methods;
— EN 1466:2004+A1:2007, Child care articles — Carry cots and stands — Safety requirements and test
methods;
— EN 14350-2:2004, Child use and care articles — Drinking equipment — Part 2: Chemical requirements
and tests;
— EN 1400-3:2002, Child use and care articles — Soothers for babies and young children — Part 3:
Chemical requirements and tests;
— EN 1400:2013+A1:2014, Child use and care articles — Soothers for babies and young children
— EN 14372:2004, Child use and care articles — Cutlery and feeding utensils — Safety requirements and
tests.
— CEN/TR 16411:2012, Child use and care articles - 2012 compiled interpretations of CEN/TC 252
standards
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2 00252033 – EN 1273:2005, Child use and care articles — Baby walking frames — Safety requirements and test
methods
Table 1 — Summary table of the request for interpretations classified in the order of the clauses/subclauses of EN 1273:2005
Clause/Subclause Title Interpretation n°
6.1.1 1/2013
6.6.2.3 1/2014 (2)
Table 2 — Table of the request for interpretation/clarification for EN 1273:2005
Clause/ Paragraph/
N° Subclause/ Figure/ Question Reply
Annex Table/Note
For the tests order shall we follow 6.1.1. but what is the “test order of the
1 6.1.1 standard” ? Is it the order of requirement §5 or order of tests methods §6 ?. In
one case the §5.9 should be done after §5.14.
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Clause/ Paragraph/
N° Subclause/ Figure/ Question Reply
Annex Table/Note
In certain designs of baby walking frames (e.g. non-castor wheels in the
back), after the sideways step test in accordance with 6.6.2.3, the product
stops with only one front wheel off the platform and with the rear wheels
almost in the initial position (see picture).
As neither in 6.6.2.3 nor 6.6.3.2 there is an
indication to change the position of the
product from the position where it has
stopped after the test in 6.6.2.3, the tip over
2 6.6.2.3 test in 6.6.3.2 shall be performed starting
from the position in which the product has
stopped after the step test in 6.6.2.3 without
The mirror committee has been made aware of a lab manually moving the
changing the position of the product or of its
product before performing the tip over test in 6.6.3.2 so that one front wheel
wheels.
and one back wheel will be off the platform.
Is the intention of the standard to perform the tip over test starting from the
position in which the product has stopped after the step test in 6.6.2.3 (see
picture above) or is it correct to move the product between 6.6.2.3 and 6.6.3.2
so that both the front and the rear wheels on one side are always off the
platform?
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3 00252059 – EN 1888:2012, Child care articles — Wheeled child conveyances — Safety requirements and test
methods
Table 3 — Summary table of the request for interpretations classified in the order of the clauses/subclauses of EN 1888:2012
Clause/Subclause Title Interpretation n°
4.5.3 Various requests 2
8.9.1.2.1 Uses of “stop” for parking 3
Table 4 — Table of the request for interpretation/clarification for EN 1888:2012
Clause/
N° Subclause/ Question Reply
Annex
No there is no reason for the difference. It’s just a
different wording.
1. There is a difference between the structure of this clause and Clauses 4.5.1
The standard makes a clear distinction on the
2 4.5.3 (paragraph 1) and Clauses 4.5.2 (paragraph 1) that begin with the words, “The
protected volume for pram bodies designed for
protected volume…”. Is there a reason for the difference?
children less than 6 months (less than 800 mm
length) and pram bodies designed for older
children (over 800 mm internal length)
No we considered that a pram body with an
internal length less than 800 mm is designed for
2. Is the clause applicable for pram bodies having a maximum internal length
children less than 6 month.
2 4.5.3 of 800 mm combined with a vehicle child conveyance for children older than 6
Of course the vehicle may be used for older
months?
children, but not in pram use (suitability and
requirements of the seat unit)
Yes the word “only” can be deleted without
3. The Experts Committee recommends that the word “only” be deleted from
modifying the purpose of this clause. The
the first sentence. Will there be any implications by this change?
2 4.5.3 protected volume described here concerns pram
Are there wheeled child conveyances designed only for children up to 6
bodies less than 800 mm long and group 0/0+ car
months?
seats mounted on a vehicle
2 6
This clause does not mention nonmetals such as phthalates. Is there a reason Yes phthalates as other hazardous substances
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Annex
for that? Is this requirement mentioned in some other required source? are already covered by a regulation (REACH)
therefore there is no need to have it into the
standard.
The purpose of the requirement is to avoid free
length inside the protected volume that will cause
a strangulation hazard. We don’t consider the
Is there any significance to the location of the connection point of the
2 8.4 attachment point of such cords straps or/ strings/
cord/string/narrow fabric?
narrow fabrics, but the length which is likely to
exceed the acceptable measure inside the
protected volume. seat unit or pram body.
Does the requirement apply to a connection located outside of the seat unit or
pram body that can be pulled into the inside of the seat unit or pram body with Yes it does
the force of 25 N?
Example 1: yes it is considered as a failure.It is a
Example 1: loop exceeding 360 mm and there is no detail in
the standard on the location of the loop.
There are seat units having a strip, for adjustment of the backrest, located at
the rear of the backrest. When pulled into the inside of the seat unit with a Example 2:
force of 25 N, the length of the strip (the part of it that is now located inside the
In English the word “located” means “attached”.
seat unit) exceeds 220 mm. Is it considered to be a failure? (see Figure A
2 8.4
bellow)
The intention of the working group was to take
into account the part of any cord/string/narrow
Figure A
fabric that can be found inside the pram body or
Example 2: seat unit, without being necessarily attached
inside the pram body or seat unit.
There are seat units having a strip, attended to be attached to the carrier's
hand, connected to the vehicle's handle. If a part of that strip penetrates to the An amendment is needed and will be drafted to
inside of the seat unit or pram body, does the requirement apply to that part of clarify this requirement.
the strip?
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Annex
Figure A
Example 2:
There are seat units having a strip, attended to be attached to the carrier's
hand, connected to the vehicle's handle. If a part of that strip penetrates to the
inside of the seat unit or pram body, does the requirement apply to that part of
the strip?
The principle of the test method is to ensure the
use of a stop has the lowest effect on the test
(possibly no effect)
To our experience there are different interpretations between different
Parking devices shall be engaged first, and then
laboratories on this point of the standard. And the confusion seems to be
the vehicle is placed on the slope.
3 8.9.1.2.1 regarding the way the wheels should be turned after putting on the brakes,
before placing the stroller against the stop. Leading to different results on
The most onerous condition shall be met (in
same product from different laboratories.
accordance with § 4) when allowing the vehicle to
rest against the stop.
The test method shall be amended.
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4 00252051 - EN 1930:2011, Child use and care articles — Safety barriers — Safety requirements and test methods
Table 5 — Summary table of the request for interpretations classified in the order of the clauses/subclauses of EN 1930:2011
Clause/Subclause Title Interpretation n°
6.4.1.3. 1/2012
Table 6 — Table of the request for interpretation/clarification for EN 1930:2011
Clause/
N° Subclause/ Question Reply
Annex
WG4 experts have discussed 6.4.1.3. and make the
following clarification:
The standard specifies in the test for barriers with a closing system
with a mechanism that closes the system without the intervention of The automatic mechanism shall always close and lock
the user that the tester shall operate the opening and closing system throughout the whole range of opening (from 0° and
1 6.4.1.3.
10 times from the maximum and minimum opening positions. The above) without the intervention of the user.
question was how the maximum and minimum opening positions are
Minimum and maximum openings may not be the most
determined.
onerous condition therefore intermediate positions shall be
checked.
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5 00252046 - EN 12586:2007, Child use and care articles – Soother holder – Safety requirements and test methods
Table 7 — Summary table of the request for interpretations classified in the order of the clauses/subclauses of EN 12586:2007
Clause/Subclause Title Interpretation n°
5.1.10 Permanent fasteners 1
3.9 ventilation hole 3
5.1.4.2 Ventilation holes 3
5.1.4.2 Migration of certain elements 4
5.1.4.2 and B.10 Surface dimension and ventilation holes 5
5.1.4.2 Hole for soother older when dealing with toy functions 6
5.1.4.2 25 mm diameter circle for ventilation hole needs? 6
5.1.12.4 and Hole for soother older when dealing with toy functions 7
5.1.4.2
5.1.4.2 Ventilation holes 8
Table 8 — Table of the request for interpretation/clarification for EN 12586:2007
Clause/
N° Subclause/ Question Reply
Annex
This subclause does not specify the checking condition of the
product.
If there is a movable part on the holder that can be placed over a
The final opinion of CEN/TC 252/WG 5 is reported in
hole of the fastener, over part of a hole of the fastener in a way to
1 5.1.10
Annex C of the current document.
reduce the passage, shall the operator check this subclause with
the movable part in all possible positions, in all possible positions
when in use, in the positions given in the instruction for use, in the
most onerous condition?
3.9 and
The main purpose of the clarification requested in Annex A is to There were no requirements in EN 12586:2007 which
3
5.1.4.2
seek guidance regarding ventilation holes in soother holder would suggest a failure of the examples given in the ASI
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N° Subclause/ Question Reply
Annex
fasteners, which do not necessarily follow the examples provided Interpretation request. The final opinion of WG 5 is reported
in EN 12586:2007. In addition the question is posed whether it is in Annex B of the current document.
possible for a ventilation hole, which entirely meets the dimension
requirements of EN 12586:2007, to have another function – such
as a facility to attach a strap. (see details in Annex B)
TC 252 WG5 follows in all of its standards the principles of
The application of the analytical correction of EN 71–3 is not clear
determination of certain elements as given in EN 71–3.
for the EN 1400–3:2002, EN 12586:2007, EN 14350–2:2004 and
EN 14372:2004. Therefore we agree that the analytical results should be
4 6.2.1
corrected as explained in EN 71–3:1995 (4.1 and 4.2) even
Do the analytical results shall be adjusted by subtracting the
though this maybe not stated specifically in some TC 252
analytical correction in Table 2 of EN 71–3 standard?
WG5 standards.
Subclause 5.1.4.2 states that any permanent fastener which
The answer to 1) is No. The first and primary requirement
protrudes past the base of guides 1 and 2 shall be provided with
(5.1.4.2) is for ventilation holes when any permanent or
ventilation holes.
detachable fastener or any permanent or detachable
supplementary component protrudes past the base of
Subclause 5.1.4.2 also states that any surface area
guides 1 and 2. This is regardless of whether there is a
encompassing a 25mm diameter circle shall include at least one
surface encompassing a 25 mm diameter circle.
ventilation hole.
The rest of the clause describes the requirements for these
1) Does it mean that if the surface on a fastener, which protrudes
ventilation holes and includes: “Any surface area
past the base of guides 1 and 2, does not encompass a 25mm
encompassing a 25 mm diameter circle shall include at
diameter circle, and then no ventilation hole is required on this
least one ventilation hole.”
fastener?
5.1.4.2 and
5
If the permanent or detachable fastener or permanent or
B.10 2) If the reply is “yes”, then how to consider the following extract
detachable supplementary component protrudes past the
of B.10”:It is considered that if any fastener or supplementary
base of guides 1 and 2, and is less than 25 mm diameter it
component is bigger than guides 1 and 2, then the risk of stuck in
shall still have a minimum of two 4 mm ventilation holes or
mouth and stuck in throat is minimal. Therefore a provision for
one 12 mm hole as described in 5.1.4.2.
ventilation hole is not required. However, if these objects are
smaller than guides 1 and 2, then ventilation holes need to be
If the permanent or detachable fastener or permanent or
provided. ?
detachable supplementary component protrudes past the
base of guides 1 and 2, and is more than 25 mm diameter,
This last sentence seems to indicate that ventilation holes are
then one of the ventilation holes shall be included in any
required provided the fastener protrudes past the base of guides
25 mm diameter circle. This is prevent manufacturers
1 and 2, and without considering the presence or not of a surface
placing ventilation holes at the very edge of the fastener for
of 25 mm diameter.
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N° Subclause/ Question Reply
Annex
example as shown in Example 1:
Note that B.10 does not explain the rationale for the surface of
25 mm diameter.
Example 1
In Example 2, wherever the 25 (dotted) circle is drawn, at
least one of the ventilation holes is included.
Example 2
The 25 mm diameter circle requirement appears in the
original standard (EN 12586:1999) and in every
subsequent revision. Therefore as there was no change in
EN 12586:2007, a rationale was not outlined.
However, the dimension was formulated by considering
every soother holder on the market in the late 1990s.
Question 1:
We were interested to note the comment from AFNOR:
“….was it the intention of WG5 to fail such products?”
Although EN 12586:2007 makes several references and
This requirement is difficult to apply when assessing this kind of
indeed requirements for soother holders with toy functions,
6 5.1.4.2
soother holder:
we believe soother holders have a very utilitarian role and
therefore do not feel comfortable with soother holders
which are designed also to be used as a toy.
We also feel that the statement: “there is no safety issue for
such components” is not entirely correct when we consider
16
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Clause/
N° Subclause/ Question Reply
Annex
the hazard of either permanently attached components or
such components becoming detached, entering the child's
throat.
Specific to the example provided by AFNOR, we feel that
such a chain with wooden or plastic parts would be quite
heavy and would pull out the soother from the child's mouth
quite easily. Although not a direct danger, it is opposite
from what is intended for a “simple” soother holder” and
perhaps would discourage the carer from using it.
That being said, 5.1.4.2 (in summary) states means that
every permanent or detachable supplementary component
protruding past the base of guides 1 and 2 shall be
provided with ventilation holes.
A strict interpretation of this clause would mean that every
bead and shape as shown in AFNOR's diagram would
require ventilation holes which we feel is correct.
Question 1 :
However, we will reconsider this issue when the soother
What are the components of a soother holder concerned by this
holder standard comes up for revision.
provision? Is this provision applicable to beads of different shape
which form the strap of this soother holder?
Question 2:
How is the wording “any surface area encompassing a 25 mm
diameter circle”? Question 2 (request of clarification):
How is this provision applicable to the different shaped beads We feel
...
SLOVENSKI STANDARD
kSIST-TP FprCEN/TR 16411:2014
01-november-2014
Izdelki za otroke - Leta 2014 zbrane interpretacije standardov CEN/TC 252
Child use and care articles - 2014 compiled interpretations of CEN/TC 252 standards
Articles de puériculture - Compilation des interprétations des normes du CEN/TC 252 en
2013
Ta slovenski standard je istoveten z: FprCEN/TR 16411
ICS:
97.190 Otroška oprema Equipment for children
kSIST-TP FprCEN/TR 16411:2014 en,fr,de
2003-01.Slovenski inštitut za standardizacijo. Razmnoževanje celote ali delov tega standarda ni dovoljeno.
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kSIST-TP FprCEN/TR 16411:2014
TECHNICAL REPORT
FINAL DRAFT
FprCEN/TR 16411
RAPPORT TECHNIQUE
TECHNISCHER BERICHT
August 2014
ICS 97.190 Will supersede CEN/TR 16411:2014
English Version
Child use and care articles - 2014 compiled interpretations of
CEN/TC 252 standards
This draft Technical Report is submitted to CEN members for Technical Committee Approval. It has been drawn up by the Technical
Committee CEN/TC 252.
CEN members are the national standards bodies 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, Slovakia, Slovenia, Spain, Sweden, Switzerland, Turkey and United
Kingdom.
Recipients of this draft are invited to submit, with their comments, notification of any relevant patent rights of which they are aware and to
provide supporting documentation.
Warning : This document is not a Technical Report. It is distributed for review and comments. It is subject to change without notice and
shall not be referred to as a Technical Report.
EUROPEAN COMMITTEE FOR STANDARDIZATION
COMITÉ EUROPÉEN DE NORMALISATION
EUROPÄISCHES KOMITEE FÜR NORMUNG
CEN-CENELEC Management Centre: Avenue Marnix 17, B-1000 Brussels
© 2014 CEN All rights of exploitation in any form and by any means reserved Ref. No. FprCEN/TR 16411:2014 E
worldwide for CEN national Members.
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Contents Page
Foreword .3
Introduction .4
1 Scope .6
2 00252033 – EN 1273:2005, Child use and care articles — Baby walking frames — Safety
requirements and test methods .7
3 00252059 – EN 1888:2012, Child care articles — Wheeled child conveyances — Safety
requirements and test methods .9
4 00252051 - EN 1930:2011, Child use and care articles — Safety barriers — Safety
requirements and test methods . 12
5 00252046 - EN 12586:2007, Child use and care articles – Soother holder – Safety
requirements and test methods . 13
6 00252048 - EN 12790:2009, Child use and care articles — Reclined cradles . 23
7 00252049 - EN 12221-1:2008, Changing units for domestic use — Part 1: Safety
requirements . 24
8 00252050 - EN 12221-2:2008, Changing units for domestic use — Part 2: Test methods . 27
9 00252054 - EN 1466:2004+A1:2007, Child care articles — Carry cots and stands — Safety
requirements and test methods . 28
10 00252032 - EN 14350-2:2004, Child use and care articles — Drinking equipment — Part 2:
Chemical requirements and tests . 31
11 00252089 - EN 1400:2013+A1:2014, Child use and care articles - Soothers for babies and
young children - Safety requirements and test methods . 32
12 00252024 - EN 14372:2004, Child use and care articles — Cutlery and feeding utensils —
Safety requirements and tests . 39
13 EN 16120:2012, Child use and care articles - Chair mounted seat . 40
14 00252067 – CEN/TR 16411:2012, Child use and care articles - 2012 compiled
interpretations of CEN/TC 252 standards . 42
Annex A (informative) Interpretation 3 on 3.9 and 5.1.4.2 in EN 12586:2007, Child use and care
articles — Soother holder — Safety requirements and test methods (WI 00252046) . 44
A.1 Introduction . 44
A.2 Examples of possible ventilation holes in more recent models of soother holders . 45
Annex B (informative) Reply to interpretation 3 on 3.9 and 5.1.4.2 in EN 12586:2007, Child use
and care articles — Soother holder — Safety requirements and test methods (WI
00252046) . 47
Annex C (informative) Reply to interpretation 1 on 5.1.10 in EN 12586:2007, Child use and care
articles — Soother holder — Safety requirements and test methods (WI 00252046) . 49
C.1 Ventilation holes in fastener (5.1.10) . 49
C.2 Discussion . 49
C.3 Final Interpretation . 54
Bibliography . 55
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Foreword
This document (FprCEN/TR 16411:2014) has been prepared by Technical Committee CEN/TC 252 “Child use
and care articles”, the secretariat of which is held by AFNOR.
This document is currently submitted to the Technical Committee Approval.
The list below shows the requests for clarification/interpretation approved since 2013 plenary meeting:
N° Standard Title Subject Doc N°
Ventilation holes for clips
1 EN 12586:2007 Soother holder (safety & test) N 1228
(5.1.4.2 (B.11) 6.1.9.2 (Figure
16&17)
Baby walking frames – Safety
2 EN 1273:2005 6.6.2.3 "tip over test" N 1266
requirements and test methods
8.1.2 "removal of the child : case
3 EN 16120:2012 Chair mounted seat N 1219
of unintentional locking device"
4.5.3 " The protected volume for
pram body",
6 "consideration of phthalates"
Wheeled child conveyances –
4 EN 1888:2012 Safety requirements and test N 1215
8.4 " connection point of the
methods
cord/string/narrow fabric and
location of the connection"
8.9.1.2.1 "brakes"
Clause 8 "Clarify of the text" in
5 EN 14350-2:2004 Drinking equipment N 1194
Product information
Soothers for babies and young Clause 6"Clarify of the text" in
6 EN 1400:2013+A1:2014 N 1194
children Product information
2012 compiled interpretations of
7 CEN/TR 16411:2012 5.1.4.2 "ventilation holes" N°1262
CEN/TC 252 standards
8 EN 12586:2007 Soother holder - Safety 5.1.4.2 "ventilation holes" N°1262
requirements and test methods
9 EN 1400:2013+A1:2014 Soothers for babies and young 8.3 "axis of shield" 1255
children
10 EN 1400:2013+A1:2014 Soothers for babies and young Various requests on the use of
children "should"
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Introduction
This Technical Report contains replies to requests for interpretation and clarifications with regard to the
understanding of clauses in the standards elaborated within the CEN/TC 252. The replies concern those
requests which have resulted in an interpretation or the decision that no action is necessary.
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 interpretation will only be regarded as a clarification of the meaning of the
standard.
a) Disclaimer:
The interpretations and clarifications have been derived by expert groups of CEN/TC 252. 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 in
the Official Journal of the European Union.
b) Requests for interpretation:
Requests for interpretations may be submitted by a CEN member body through its national committee or by a
CEN/TC 252 liaison (but not directly by an individual or a company) - in accordance with the interpretation
protocols agreed by CEN/TC 252. The requests are then channelled to the relevant CEN/TC 252 working
group which will deal with the request.
A request for an interpretation may lead to:
1) an interpretation of the standard:
this should reflect a reasonable interpretation of how the standard should be used, while taking into
account:
i) the wording of the standard;
ii) the rationale of the standard;
iii) the history of the standard;
2) a no-action decision:
this is applicable when it is agreed that the standard appropriately specifies how a child care article shall
be assessed;
3) a proposal for an amendment of the standard:
this is applicable when it is agreed that the standard is deficient in some way.
NOTE Interpretation are published in CEN/TR 16411, which will be updated on a regular basis.
Proposals for amendments will be progressed as new work item proposals in accordance with CEN rules.
c) Answers to requests for interpretations:
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Since requests for interpretations are submitted through a CEN member body, it is assumed that the member
body will keep itself informed about decisions concerning the request and its progress and will itself inform the
originator of the request as appropriate.
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1 Scope
The purpose of this Technical Report is to provide replies to requests for interpretations and clarifications of:
— EN 1273:2005, Child use and care articles — Baby walking frames — Safety requirements and test
methods;
— EN 1888:2012, Child care articles — Wheeled child conveyances — Safety requirements and test
methods;
— EN 1930:2011, Child use and care articles — Safety barriers — Safety requirements and test methods;
— EN 12586:2007, Child use and care articles — Soother holder — Safety requirements and test methods;
— EN 12790:2009, Child use and care articles — Reclined cradles;
— EN 12221-1:2008, Changing units for domestic use — Part 1: Safety requirements;
— EN 12221-2:2008, Changing units for domestic use — Part 2: Test methods;
— EN 1466:2004+A1:2007, Child care articles — Carry cots and stands — Safety requirements and test
methods;
— EN 14350-2:2004, Child use and care articles — Drinking equipment — Part 2: Chemical requirements
and tests;
— EN 1400-3:2002, Child use and care articles — Soothers for babies and young children — Part 3:
Chemical requirements and tests;
— EN 1400:2013+A1:2014 Child use and care articles — Soothers for babies and young children;
— EN 14372:2004, Child use and care articles — Cutlery and feeding utensils — Safety requirements and
tests;
— EN 12586:2007, Child use and care articles — Soother holder — Safety requirements and test methods;
— CEN/TR 16411:2012, Child use and care articles — 2012 compiled interpretations of CEN/TC 252
standards
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2 00252033 – EN 1273:2005, Child use and care articles — Baby walking frames — Safety requirements and test
methods
Table 1 — Summary table of the request for interpretations classified in the order of the clauses/subclauses of EN 1273:2005
Clause/Subclause Title Interpretation n°
6.1.1 1/2013
6.6.2.3 1/2014 (2)
Table 2 — Table of the request for interpretation/clarification for EN 1273:2005
Clause/ Paragraph/
N° Subclause/ Figure/ Question Reply
Annex Table/Note
For the tests order shall we follow 6.1.1. but what is the “test order of the
1 6.1.1 standard” ? Is it the order of requirement §5 or order of tests methods §6 ?. In
one case the §5.9 should be done after §5.14.
In certain designs of baby walking frames (e.g. non-castor wheels in the
back), after the sideways step test in accordance with 6.6.2.3, the product
stops with only one front wheel off the platform and with the rear wheels
almost in the initial position (see picture).
As neither in clause 6.6.2.3 nor 6.6.3.2
there is an indication to change the position
of the product from the position where it
has stopped after the test in 6.6.2.3, the tip
2 6.6.2.3 over test in clause 6.6.3.2 shall be
performed starting from the position in
which the product has stopped after the
step test in 6.6.2.3 without changing the
The mirror committee has been made aware of a lab manually moving the
position of the product or of its wheels.
product before performing the tip over test in 6.6.3.2 so that one front wheel
and one back wheel will be off the platform.
Is the intention of the standard to perform the tip over test starting from the
position in which the product has stopped after the step test in 6.6.2.3 (see
picture above) or is it correct to move the product between 6.6.2.3 and 6.6.3.2
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so that both the front and the rear wheels on one side are always off the
platform?
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3 00252059 – EN 1888:2012, Child care articles — Wheeled child conveyances — Safety requirements and test
methods
Table 3 — Summary table of the request for interpretations classified in the order of the clauses/subclauses of EN 1888:2012
Clause/Subclause Title Interpretation n°
4.5.3 Various requests 2
8.9.1.2.1 Uses of "stop" for parking 3
Table 4 — Table of the request for interpretation/clarification for EN 1888:2012
Clause/
N° Subclause/ Question Reply
Annex
No there is no reason for the difference. It’s just a
different wording.
1. There is a difference between the structure of this clause and clauses 4.5.1
The standard makes a clear distinction on the
2 4.5.3 (paragraph 1) and clauses 4.5.2 (paragraph 1) that begin with the words, "The
protected volume for pram bodies designed for
protected volume…". Is there a reason for the difference?
children less than 6 months ( less than 800 mm
length) and pram bodies designed for older
children (over 800 mm internal length)
No we considered that a pram body with an
internal length less than 800 mm is designed for
2. Is the clause applicable for pram bodies having a maximum internal length
children less than 6 month.
2 4.5.3 of 800 mm combined with a vehicle child conveyance for children older than 6
Of course the vehicle may be used for older
months?
children, but not in pram use (suitability and
requirements of the seat unit)
Yes the word “only” can be deleted without
3. The Experts Committee recommends that the word "only" be deleted from
modifying the purpose of this clause. The
the first sentence. Will there be any implications by this change?
2 4.5.3 protected volume described here concerns pram
Are there wheeled child conveyances designed only for children up to 6
bodies less than 800 mm long and group 0/0+ car
months?
seats mounted on a vehicle
2 6
This clause does not mention nonmetals such as phthalates. Is there a reason Yes phthalates as other hazardous substances
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for that? Is this requirement mentioned in some other required source? are already covered by a regulation (REACH)
therefore there is no need to have it into the
standard.
The purpose of the requirement is to avoid free
length inside the protected volume that will cause
a strangulation hazard. We don’t consider the
Is there any significance to the location of the connection point of the
2 8.4 attachment point of such cords strings/ narrow
cord/string/narrow fabric?
fabrics, but the length which is likely to exceed
the acceptable measure inside the seat unit or
pram body.
Yes it does
Does the requirement apply to a connection located outside of the seat unit or
pram body that can be pulled into the inside of the seat unit or pram body with Example 1: yes it is considered as a failure.It is a
the force of 25 N? loop exceeding 360 mm and there is no detail in
the standard on the location of the loop.
Example 1:
There are seat units having a strip, for adjustment of the backrest, located at
the rear of the backrest. When pulled into the inside of the seat unit with a Example 2:
force of 25 N, the length of the strip (the part of it that is now located inside the
In English the word “located” means “attached”.
seat unit) exceeds 220 mm. Is it considered to be a failure? (see Figure A
2 8.4
bellow)
The intention of the working group was to take
into account the part of any cord/string/narrow
Figure A
fabric that can be found inside the pram body or
Example 2: seat unit, without being necessarily attached
inside the pram body or seat unit.
There are seat units having a strip, attended to be attached to the carrier's
hand, connected to the vehicle's handle. If a part of that strip penetrates to the
inside of the seat unit or pram body, does the requirement apply to that part of
An amendment is needed and will be drafted to
the strip?
clarify this requirement.
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Figure A
Example 2:
There are seat units having a strip, attended to be attached to the carrier's
hand, connected to the vehicle's handle. If a part of that strip penetrates to the
inside of the seat unit or pram body, does the requirement apply to that part of
the strip?
The principle of the test method is to ensure the
use of a stop has the lowest effect on the test
(possibly no effect)
To our experience there are different interpretations between different labs on
Parking devices shall be engaged first, and then
this point of the standard. And the confusion seems to be regarding the way
the vehicle is placed on the slope.
3 8.9.1.2.1 the wheels should be turned after putting on the brakes, before placing the
stroller against the stop. Leading to different results on same product from
The most onerous condition shall be met (in
different labs.
accordance with § 4) when allowing the vehicle to
rest against the stop.
The test method shall be amended.
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4 00252051 - EN 1930:2011, Child use and care articles — Safety barriers — Safety requirements and test methods
Table 5 — Summary table of the request for interpretations classified in the order of the clauses/subclauses of EN 1930:2011
Clause/Subclause Title Interpretation n°
6.4.1.3. 1/2012
Table 6 — Table of the request for interpretation/clarification for EN 1930:2011
Clause/
N° Subclause/ Question Reply
Annex
WG4 experts have discussed 6.4.1.3. and make the
following clarification:
The standard specifies in the test for barriers with a closing system
with a mechanism that closes the system without the intervention of The automatic mechanism shall always close and lock
the user that the tester must operate the opening and closing system throughout the whole range of opening (from 0º and
1 6.4.1.3.
10 times from the maximum and minimum opening positions. The above) without the intervention of the user.
question was how the maximum and minimum opening positions are
Minimum and maximum openings may not be the most
determined.
onerous condition therefore intermediate positions shall be
checked.
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5 00252046 - EN 12586:2007, Child use and care articles – Soother holder – Safety requirements and test methods
Table 7 — Summary table of the request for interpretations classified in the order of the clauses/subclauses of EN 12586:2007
Clause/Subclause Title Interpretation n°
5.1.10 Permanent fasteners 1
3.9 Ventilation hole 3
5.1.4.2 Ventilation holes 3
5.1.4.2 Migration of certain elements 4
5.1.4.2 & B.10 Surface dimension and ventilation holes 5
5.1.4.2 Hole for soother older when dealing with toy functions 6
5.1.4.2 25 mm diameter circle for ventilation hole needs? 6
5.1.12.4 & 5.1.4.2 Hole for soother older when dealing with toy functions 7
5.1.4.2 Ventilation holes 8
Table 8 — Table of the request for interpretation/clarification for EN 12586:2007
Clause/
N° Subclause/ Question Reply
Annex
This subclause does not specify the checking condition of the
product.
If there is a movable part on the holder that can be placed over a
The final opinion of CEN/TC 252/WG 5 is reported in Annex
hole of the fastener, over part of a hole of the fastener in a way to
1 5.1.10
C of the current document.
reduce the passage, shall the operator check this subclause with
the movable part in all possible positions, in all possible positions
when in use, in the positions given in the instruction for use, in the
most onerous condition?
The main purpose of the clarification requested in Annex A is to There were no requirements in EN 12586:2007 which
3.9 &
3
seek guidance regarding ventilation holes in soother holder would suggest a failure of the examples given in the ASI
5.1.4.2
fasteners, which do not necessarily follow the examples provided Interpretation request. The final opinion of WG 5 is reported
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in EN 12586:2007. In addition the question is posed whether it is in Annex B of the current document.
possible for a ventilation hole, which entirely meets the dimension
requirements of EN 12586:2007, to have another function – such
as a facility to attach a strap. (see details in Annex B)
TC 252 WG5 follows in all of its standards the principles of
The application of the analytical correction of EN 71-3 is not clear
determination of certain elements as given in EN 71-3.
for the EN 1400-3:2002, EN 12586:2007, EN 14350-2:2004 and
EN 14372:2004. Therefore we agree that the analytical results should be
6.2.1
4
corrected as explained in EN 71-3:1995 (4.1 and 4.2) even
Do the analytical results shall be adjusted by subtracting the
though this maybe not stated specifically in some TC 252
analytical correction in Table 2 of EN 71-3 standard?
WG5 standards.
Subclause 5.1.4.2 states that any permanent fastener which
The answer to 1) is No. The first and primary requirement
protrudes past the base of guides 1 and 2 shall be provided with
(5.1.4.2) is for ventilation holes when any permanent or
ventilation holes.
detachable fastener or any permanent or detachable
supplementary component protrudes past the base of
Subclause 5.1.4.2 also states that any surface area
guides 1 and 2. This is regardless of whether there is a
encompassing a 25mm diameter circle shall include at least one
surface encompassing a 25 mm diameter circle.
ventilation hole.
The rest of the clause describes the requirements for these
1) Does it mean that if the surface on a fastener, which protrudes
ventilation holes and includes: "Any surface area
past the base of guides 1 and 2, does not encompass a 25mm
encompassing a 25 mm diameter circle shall include at
diameter circle, and then no ventilation hole is required on this
least one ventilation hole."
fastener?
5.1.4.2 &
If the permanent or detachable fastener or permanent or
2) If the reply is “yes”, then how to consider the following extract
5
B.10
detachable supplementary component protrudes past the
of Annex B.10 :”It is considered that if any fastener or
base of guides 1 and 2, and is less than 25 mm diameter it
supplementary component is bigger than guides 1 and 2, then the
shall still have a minimum of two 4 mm ventilation holes or
risk of stuck in mouth and stuck in throat is minimal. Therefore a
one 12 mm hole as described in 5.1.4.2.
provision for ventilation hole is not required. However, if these
objects are smaller than guides 1 and 2, then ventilation holes
If the permanent or detachable fastener or permanent or
need to be provided. ?
detachable supplementary component protrudes past the
base of guides 1 and 2, and is more than 25 mm diameter,
This last sentence seems to indicate that ventilation holes are
then one of the ventilation holes must be included in any 25
required provided the fastener protrudes past the base of guides
mm diameter circle. This is prevent manufacturers placing
1 and 2, and without considering the presence or not of a surface
ventilation holes at the very edge of the fastener for
of 25 mm diameter.
example as shown in Example 1:
Note that Clause B.10 does not explain the rationale for the
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surface of 25 mm diameter.
Example 1
In Example 2, wherever the 25 (dotted) circle is drawn, at
least one of the ventilation holes is included.
Example 2
The 25 mm diameter circle requirement appears in the
original standard (EN 12586:1999) and in every
subsequent revision. Therefore as there was no change in
EN 12586:2007, a rationale was not outlined.
However, the dimension was formulated by considering
every soother holder on the market in the late 1990's.
Question 1:
We were interested to note the comment from AFNOR:
"….was it the intention of WG5 to fail such products?"
Although EN 12586:2007 makes several references and
This requirement is difficult to apply when assessing this kind of
indeed requirements for soother holders with toy functions,
6 5.1.4.2
soother holder:
we believe soother holders have a very utilitarian role and
therefore do not feel comfortable with soother holders
which are designed also to be used as a toy.
We also feel that the statement: "there is no safety issue for
such components" is not entirely correct when we consider
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the hazard of either permanently attached components or
such components becoming detached, entering the child's
throat.
Specific to the example provided by AFNOR, we feel that
such a chain with wooden or plastic parts would be quite
heavy and would pull out the soother from the child's mouth
quite easily. Although not a direct danger, it is opposite
from what is intended for a "simple" soother holder" and
perhaps would discourage the carer from using it.
That being said, Subclause 5.1.4.2 (in summary) states
Question 1 :
means that every permanent or detachable supplementary
component protruding past the base of guides 1 and 2 shall
What are the components of a soother holder concerned by this
be provided with ventilation holes.
provision? Is this provision applicable to beads of different shape
which form the strap of this soother holder?
A strict interpretation of this clause would mean that every
bead and shape as shown in AFNOR's diagram would
require ventilation holes which we feel is correct.
However, we will reconsider this issue when the soother
holder standard comes up for revision.
Question 2:
How is the wording “any surface area
...
Questions, Comments and Discussion
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