SIST-TP CEN/TR 16411:2012
(Main)Child use and care articles - 2012 compiled interpretations of CEN/TC 252 standards
Child use and care articles - 2012 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 1888:2003, Child care articles - Wheeled child conveyances - Safety requirements and test methods
- EN 1888:2003/A1:2005, Child care articles - Wheeled child conveyances - Safety requirements and test methods
- EN 1888:2003/A2:2005, Child care articles - Wheeled child conveyances - Safety requirements and test methods
- EN 1888:2003/A3:2005, Child care articles - Wheeled child conveyances - Safety requirements and test methods
- EN 12586:2007, Child use and care articles - Soother holder - Safety requirements and methods
- EN 12790:2009, Child use and care articles - Reclined cradles
- EN 12221-1:2008, Child use and care articles - Changing units for domestic use - Part 1: Safety requirements
- EN 12221-2:2008, Child use and care articles - Changing units for domestic use - Part 2: Test methods
- EN 1466:2004+A1:2007, Child use and care articles - Carry cots and stands - Safety requirements and test methods
Artikel für Säuglinge und Kleinkinder - Gesammelte Interpretationen der CEN/TC 252-Normen 2012
Articles de puériculture - Compilation des interprétations des normes du CEN/TC 252 en 2012
Izdelki za otroke - Leta 2012 zbrane interpretacije in razlaga standardov CEN/TC 252
Namen tega tehničnega poročila CEN je zagotoviti odgovore na zahteve za razlago in pojasnilo naslednjih standardov: - EN 1888:2003, Izdelki za otroke – Otroški vozički – Varnostne zahteve in preskusne metode – EN 1888:2003/A1:2005, Izdelki za otroke – Otroški vozički – Varnostne zahteve in preskusne metode – EN 1888:2003/A2:2005, Izdelki za otroke – Otroški vozički – Varnostne zahteve in preskusne metode – EN 1888:2003/A3:2005, Izdelki za otroke – Otroški vozički – 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, Izdelki za otroke – Previjalne mize za domačo uporabo – 1. del: Varnostne zahteve – EN 12221-2:2008, Izdelki za otroke – 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.
General Information
Relations
Standards Content (Sample)
SLOVENSKI STANDARD
SIST-TP CEN/TR 16411:2012
01-december-2012
Izdelki za otroke - Leta 2012 zbrane interpretacije in razlaga standardov CEN/TC
252
Child use and care articles - 2012 compiled interpretations of CEN/TC 252 standards
Artikel für Säuglinge und Kleinkinder - Gesammelte Interpretationen der CEN/TC 252-
Normen 2012
Articles de puériculture - Compilation des interprétations des normes du CEN/TC 252 en
2012
Ta slovenski standard je istoveten z: CEN/TR 16411:2012
ICS:
97.190 Otroška oprema Equipment for children
SIST-TP CEN/TR 16411:2012 en
2003-01.Slovenski inštitut za standardizacijo. Razmnoževanje celote ali delov tega standarda ni dovoljeno.
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SIST-TP CEN/TR 16411:2012
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SIST-TP CEN/TR 16411:2012
TECHNICAL REPORT
CEN/TR 16411
RAPPORT TECHNIQUE
TECHNISCHER BERICHT
September 2012
ICS 97.190
English Version
Child use and care articles - 2012 compiled interpretations of
CEN/TC 252 standards
Articles de puériculture - Compilation des interprétations Artikel für Säuglinge und Kleinkinder - Gesammelte
des normes du CEN/TC 252 en 2012 Interpretationen der CEN/TC 252-Normen 2012
This Technical Report was approved by CEN on 6 August 2012. 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
Management Centre: Avenue Marnix 17, B-1000 Brussels
© 2012 CEN All rights of exploitation in any form and by any means reserved Ref. No. CEN/TR 16411:2012: E
worldwide for CEN national Members.
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CEN/TR 16411:2012 (E)
Contents Page
Foreword .3
Introduction .3
1 Scope .5
2 00252009 – EN 1888:2003, Child care articles - Wheeled child conveyances - Safety
requirements and test methods .6
3 00252039 – EN 1888:2003/A1:2005, Child care articles - Wheeled child conveyances -
Safety requirements and test methods . 10
4 00252040 – EN 1888:2003/A2:2005, Child care articles - Wheeled child conveyances -
Safety requirements and test methods . 10
5 00252041 – EN 1888:2003/A3:2005, Child care articles - Wheeled child conveyances -
Safety requirements and test methods . 11
6 00252046 - EN 12586:2007, Child use and care articles – Soother holder – Safety
requirements and methods . 12
7 00252048 - EN 12790:2009, Child use and care articles - Reclined cradles . 20
8 00252049 - EN 12221-1:2008, Child use and care articles - Changing units for domestic
use – Part 1: Safety requirements . 21
9 00252050 - EN 12221-2:2008, Child use and care articles - Changing units for domestic
use - Part 2: Test methods . 23
10 00252054 - EN 1466:2004+A1:2007, Child use and care articles - Carry cots and stands —
Safety requirements and test methods . 24
11 EN 14350-2:2004, Child use and care articles - Drinking equipment - Part 2: chemical
requirements and tests . 27
12 EN 1400-3:2002, Child use and care articles - Soothers for babies and young children -
Part 3: chemical requirements and tests . 27
13 EN 14372:2004, Child use and care articles - Cutlery and feeding utensils - Safety
requirements and tests, and, . 28
Annex A (informative) Interpretation 3 on the 3.9 and 5.1.4.2 of the EN 12586:2007, Child use and
care articles – Soother holder – Safety requirements and method (WI 00252046) . 29
Annex B (informative) Reply to interpretation 3 on the 3.9 and 5.1.4.2 of the EN 12586:2007, Child
use and care articles – Soother holder – Safety requirements and method (WI 00252046) . 32
Annex C (informative) Reply to interpretation 1 on the 5.1.10 of the EN 12586:2007, Child use and
care articles – Soother holder – Safety requirements and method (WI 00252046) . 34
Bibliography . 40
2
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Foreword
This document (CEN/TR 16411:2012) has been prepared by Technical Committee CEN/TC 252 “Child use
and care articles”, the secretariat of which is held by AFNOR.
Introduction
Interpretations and no-action decisions
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 shall only be regarded as a clarification of the meaning of the
standard.
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.
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:
a) An interpretation of the standard
This should reflect a reasonable interpretation of how the standard should be used, taking into account
the wording of the standard
the rationale of the standard
the history of the standard
b) A no-action decision
This is applicable when it is agreed that the standard appropriately specifies how a child care article shall
be assessed.
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c) 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 and no-action decisions 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.
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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CEN/TR 16411:2012 (E)
1 Scope
The purpose of this CEN Technical Report is to provide replies to requests for interpretations and clarifications
of:
EN 1888:2003, Child care articles - Wheeled child conveyances - Safety requirements and test methods
EN 1888:2003/A1:2005, Child care articles - Wheeled child conveyances - Safety requirements and test
methods
EN 1888:2003/A2:2005, Child care articles - Wheeled child conveyances - Safety requirements and test
methods
EN 1888:2003/A3:2005, Child care articles - Wheeled child conveyances - Safety requirements and test
methods
EN 12586:2007, Child use and care articles – Soother holder – Safety requirements and methods
EN 12790:2009, Child use and care articles - Reclined cradles
EN 12221-1:2008, Child use and care articles - Changing units for domestic use – Part 1: Safety
requirements
EN 12221-2:2008, Child use and care articles - Changing units for domestic use - Part 2: Test methods
EN 1466:2004+A1:2007, Child use and care articles - Carry cots and stands — Safety requirements and
test methods
.
5
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2 00252009 – EN 1888:2003, Child care articles - Wheeled child conveyances - Safety requirements and test methods
Table 1 — Summary table of the request for interpretations classified in the order of the clauses/subclauses of the EN 1888:2003
Clause/Subclause Title Interpretation n°
6.1.5 Attachment of mechanical parts 6
6.1.7 Pram body or seat unit internal lining 4
11 Locking devices for the folding mechanism 2
11.2 Test for locking devices 1
18 Dynamic strength 3
21.1 General (Product information) 5
Table 2 — Interpretations
Clause/ Paragraph/
N° Subclause/ Figure/ Question Reply
Annex Table/Note
After performing some comparative tests in different laboratories
on the same item (a stroller), we found that test method for test
11.2 is not completely defined in EN 1888:2003; as a matter of
fact, different methods applied by different laboratories lead to
completely different results (failure or approval). In particular, the
sentence "Restrain the vehicle without impeding its folding" can
1 11.2
be interpreted in different ways, leading to these extreme testing
situations:
put the stroller with the front wheels against some stops and
restrain the vehicle to avoid its tipping over, for example by
attaching a cord under the stroller to fix it to the floor. Pull
then the handle with a force of 200N. In case of separate
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Clause/ Paragraph/
N° Subclause/ Figure/ Question Reply
Annex Table/Note
handles pull each handle separately with 200N.
This test is supposed to assess the strength of the
locking devices during use. Therefore "without impeding
put the stroller on the floor without stopping the front wheels
its folding" means that during test, the vehicle is still
and restrain the vehicle to avoid its movement and tipping
able to absorb the force applied.
over by fixing one of the rear wheels to the floor. Pull then the
The requirement of subclause 11.1 ("when tested in
handle with a force of 200N. In case of separate handles pull
accordance with 11.2, any subsequent folding travel
each handle separately with 200N.
shall comply with the requirements of 6.1.1, 6.1.2 and
1 11.2
The two test methods distribute the force on the frame of the
6.1.3. The vehicle shall not fold and the locking
stroller in a very different way and this may lead to different
device(s) shall not be released") shall be checked after
results for the “same” test. It is necessary to amend the current
the force has been applied and the product being
test method in order to clearly define the testing conditions in
erected for use again (all locking devices locked), in
such a way that every laboratory will get the same results when
order to control if any effect such as strain may create
testing the same item with the same method.
entrapment hazards, crushing hazards, and dangerous
edges or corners due to failure of any locking device.
a) NO, it is not the intention of the committee to fail
this kind of product.
b) Development
Locking devices are required to prevent a vehicle
folding whilst a child is in the vehicle, and also
during the process of the child being put in and
taken out of the vehicle. Any locking device(s) for
the folding mechanism shall be positioned so that it
is not possible to operate more than one device in a
single action.
2 11
To avoid the hazards due to inadvertent operation
by the adult or operations by a child, there shall be
at least two locking devices, to be released, one of
them shall require:
1) two separate operations acting on two
separate parts of the vehicle; or
Key
2) two consecutive actions, the first being
1 Push up to unlock with left foot
maintained while the second is carried out.
2 Push down with right foot, to release and enable folding
To avoid the hazards due to incomplete
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Clause/ Paragraph/
N° Subclause/ Figure/ Question Reply
Annex Table/Note
Figure 1 — Stroller with a standard folding lock deployment at least one of the locking devices shall
engage automatically.
Illustrated above is a picture of a stroller with a standard folding
lock arrangement of a type that has been supplied for many c) Proposal for interpretation
years, without adverse safety comments.
Release: if (when the product is fully erected and
ready for use) any of the locking devices
considered has to be maintained operated, it shall
not be considered as being released.
The design of the folding mechanism lock complies with the
requirements of the UK standard BS 7409: 1996. A UK test
laboratory has failed folding mechanisms of this type to EN
1888:2003 clause 11 (Locking devices for the folding
In that case check if the system complies with b),
mechanism), in their opinion neither one of the 2 locking devices
considering that the second operation or action
satisfies 11.1a) or b).
may be operated on the second device.
As mentioned strollers with this type locking device have been
⌦⌦⌦⌦ Clause 11 of the consolidated version of EN 1888
supplied in large quantities by many different manufacturers for
shall be amended.
more that a decade without any adverse reports of inadvertent
operation of the locking devices etc.
Is it the intention of the committee that this type of design should
fail EN 1888?
After test in accordance with 18.2, the vehicle shall not be a) The aim of the requirement is to check the strength
damaged such as its safety is impaired. .This is verified following of the attachment devices for the seat unit or pram
order of tests given in clause 4.2. body to the chassis.
The prambody or seat unit shall not be displaced by more than 10 b) Soft carry cots attached to the chassis shall comply
mm on the chassis after testing in accordance with 18.2 in every with this requirement.
direction.
⌦⌦ Risks linked to the use of soft carry cots fitted to a
⌦⌦
Lets consider a carrycot attached to a pushchair by the mean of
3 18 pram body or seat unit shall be addressed by revision of
straps fitted with clips, requirements of clause 14 being met. EN1888.
NOTE Carrycots fitted on a pushchair are considered as seat units
in accordance with the definition given in clause 3.3.
a) What is the rationale of the requirement 18.1 (no
displacement greater than 10 mm) ?
b) Is this requirement applicable to soft carrycots?
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Clause/ Paragraph/
N° Subclause/ Figure/ Question Reply
Annex Table/Note
We need clarification on the meaning of tension of internal lining The risk to be covered is the risk of suffocation due to
of the pram body or seat unit. loose fabric parts.
4 6.1.7
Which risk should be covered? The standard is clear enough to cover the risk.
An European standard, the CEI/TR 62017-1:2001
Product information – General : the standard precises:
dealing with product information gives details.
"The warning sentences shall be written in letters at least 10
A typographic ruler (normograph) can be used to
points in height. The word "WARNING" shall be written in upper
directly check that the height of letters is 10 points.
5 21.1
case."
⌦⌦⌦⌦ The wording will be changed in the revision of the
a) What is the measurement to assess this requirement?
standard to be in line with CEN/CENELEC Guidelines
b) Are all letters concerned?
11.
We need precision on the type of parts for which this clause
The proposal is not an interpretation, but changes the
applies and how.
standard.
As the 90 N force corresponds to the force that a child is able to
6 6.1.5
This clause is applicable to the whole product.
apply on parts and in line with relevant risk analysis we decide to
apply this requirement within the access zone, as described within
⌦⌦⌦⌦ Wording will be improved during the revision work.
previous clauses of the standard.
9
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3 00252039 – EN 1888:2003/A1:2005, 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 the EN 1888:2003/A1:2005
Clause/Subclause Title Interpretation n°
15.1.2 Harness anchorage points 1
Table 4 — Interpretations
Clause/ Paragraph/
N° Subclause/ Figure/ Question Reply
Annex Table/Note
The amendment A1 requires in subclause 15.1.2:
"Seat units and pram bodies with an internal length greater than
The 800 mm internal length refers to prambodies.
800 mm (see 6.2.1) shall be fitted with two harness anchorage
The aim of these attachment points is to allow a carer to
points for each position that a child can occupy"
1 15.1.2 use a separate harness.
As a seat unit shall be equipped with a child restraint system
Even a seat unit fitted with a child restraint system shall
conforming to the requirements of the standard and its
be fitted with two anchorage points.
amendment, shall we ask for additional anchoring points ?
What does "for each position that a child can occupy" mean ?
4 00252040 – EN 1888:2003/A2:2005, Child care articles - Wheeled child conveyances - Safety requirements and test
methods
Table 5 — Summary table of the request for interpretations classified in the order of the clauses/subclauses of the EN 1888:2003/A2:2005
Clause/Subclause Title Interpretation n°
4.5.2.8 Test mass F 1
Table 6 — Interpretations
N° Question Reply
Clause/ Paragraph/
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Subclause/ Figure/
Annex Table/Note
The amendment A2 requires in subclause 4.5.2.8 a test mass F,
initially designed to be used for tests of combinations pushchair /
group 0+ car seat.
The standard as it is cannot be changed and until the
revision the 15 kg test mass shall be used.
1 4.5.2.8 The use of this test mass has not been described in some clauses
for relevant tests. As the limit of use of such products is 13 kg in
⌦⌦ This shall be addressed during a revision.
⌦⌦
weight, is it possible to use this test mass F where it is relevant?
(i.e. stability, parking device as irregular surface tests …)
5 00252041 – EN 1888:2003/A3:2005, Child care articles - Wheeled child conveyances - Safety requirements and test
methods
Table 7 — Summary table of the request for interpretations classified in the order of the clauses/subclauses of the EN 1888:2003/A3:2005
Clause/Subclause Title Interpretation n°
6.1.8 Attachment of textile parts with child retention purpose 1
Table 8 — Interpretations
Clause/ Paragraph/
N° Subclause/ Figure/ Question Reply
Annex Table/Note
As it is written, the text may be applicable to any existing product,
This requirement is only applicable to seat units
as soon as a textile part is provided, where it gives the impression
convertible into a prambody by adding textile parts and
that a retention purpose is met.
1 6.1.8 which are not equipped with a restraint system
This wording shall be clarified and improved. adjustable to the child's size from birth and complying
with clause 15.
It shall be clearly determined, when the test is applicable.
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6 00252046 - EN 12586:2007, Child use and care articles – Soother holder – Safety requirements and methods
Table 9 — Summary table of the request for interpretations classified in the order of the clauses/subclauses of the 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
Table 10 — Interpretations
Clause/ Paragraph/
N° Subclause/ Figure/ Question Reply
Annex Table/Note
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
1 5.1.10 hole of the fastener, over part of a hole of the fastener in a way to
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 ?
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Clause/ Paragraph/
N° Subclause/ Figure/ Question Reply
Annex Table/Note
The main purpose of the clarification requested in Annex A is to
seek guidance regarding ventilation holes in soother holder
There were no requirements in EN 12586:2007 which
fasteners, which do not necessarily follow the examples provided
3.9 & would suggest a failure of the examples given in the ASI
3
in EN 12586:2007. In addition the question is posed whether it is
5.1.4.2 Interpretation request. The final opinion of WG 5 is
possible for a ventilation hole, which entirely meets the dimension
reported in Annex B of the current document.
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 determination of certain elements as given in EN71-
The application of the analytical correction of EN 71-3 is not clear
3.
for the EN 1400-3:2002, EN 12586:2007, EN 14350-2 :2004 & EN
Therefore we agree that the analytical results should be
14372:2004.
4 6.2.1
corrected as explained in EN71-3:1995 (4.1 and 4.2)
Do the analytical results shall be adjusted by subtracting the
even though this maybe
analytical correction in table 2 of EN 71-3 standard?
not stated specifically in some TC 252 WG5
standards.
Clause 5.1.4.2 states that any permanent fastener which
The answer to 1) is No. The first and primary
protrudes past the base of guides 1 and 2 shall be provided with
requirement (5.1.4.2) is for ventilation holes when any
ventilation holes.
permanent or detachable fastener or any permanent or
detachable supplementary component protrudes past
Clause 5.1.4.2 also states that any surface area encompassing a
the base of guides 1 and 2. This is regardless of
25mm diameter circle shall include at least one ventilation hole.
whether there is a surface encompassing a 25 mm
1) Does it mean that if the surface on a fastener, which protrudes
diameter circle.
past the base of guides 1 and 2, does not encompass a 25mm
The rest of the clause describes the requirements for
diameter circle, then no ventilation hole is required on this
5.1.4.2 & these ventilation holes and includes: "Any surface area
fastener?
5
B.10 encompassing a 25 mm diameter circle shall include at
2) If the reply is “yes”, then how to consider the following extract
least one ventilation hole."
of Annex B.10 :”It is considered that if any fastener or
If the permanent or detachable fastener or permanent
supplementary component is bigger than guides 1 and 2, then the
or detachable supplementary component protrudes past
risk of stuck in mouth and stuck in throat is minimal. Therefore a
the base of guides 1 and 2, and is less than 25 mm
provision for ventilation hole is not required. However, if these
diameter it shall still have a minimum of two 4 mm
objects are smaller than guides 1 and 2, then ventilation holes
ventilation holes or one 12 mm hole as described in
need to be provided. ?
5.1.4.2.
This last sentence seems to indicate that ventilation holes are
If the permanent or detachable fastener or permanent
required provided the fastener protrudes past the base of guides
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Clause/ Paragraph/
N° Subclause/ Figure/ Question Reply
Annex Table/Note
1 and 2, and without considering the presence or not of a surface or detachable supplementary component protrudes past
of 25mm diameter. the base of guides 1 and 2, and is more than 25 mm
diameter, then one of the ventilation holes must be
Note that Annex B.10 does not explain the rationale for the
included in any 25 mm diameter circle. This is prevent
surface of 25mm diameter.
manufacturers placing ventilation holes at the very edge
of the fastener for example as shown in Example 1:
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:
This requirement is difficult to apply when assessing this kind of
6 5.1.4.2
We were interested to note the comment from AFNOR:
soother holder:
"….was it the intention of WG5 to fail such products?"
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Clause/ Paragraph/
N° Subclause/ Figure/ Question Reply
Annex Table/Note
Although EN 12586:2007 makes several references and
indeed requirements for soother holders with toy
functions, 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 the hazard of either permanently attached
components or such components becoming detached,
entering the child's throat.
Question 1 :
Specific to the example provided by AFNOR, we feel
What are the components of a soother holder concerned by this
that such a chain with wooden or plastic parts would be
provision? Is this provision applicable to beads of different shape
quite heavy and would pull out the soother from the
which form the strap of this soother holder?
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, Clause 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.
However, we will reconsider this issue when the soother
holder standard comes up for revision.
15
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SIST-TP CEN/TR 16411:2012
CEN/TR 16411:2012 (E)
Clause/ Paragraph/
N° Subclause/ Figure/ Question Reply
Annex Table/Note
Question 2:
How is the wording “any surface area encompassing a
...
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