“Designing for Compliance” is critical to getting your product certified on the first try. Designing for Compliancerequires owning, knowing, and applying the standard(s) while designing your product. However, in order to
successfully read and understand the standard, you have to know the intent of the requirements. Our “Designing
for Compliance” series of whitepapers will educate you on “The 6 Hazards of Product Safety”. The intent of the
requirements in all UL/CSA/EN/IEC safety standards is to protect the user from the “6 Hazards of Product
Safety”. This whitepaper covers Hazard #6 – Risk of Chemicals.
Risk of Chemicals Definition: The definition for this hazard is in a slow transition. Traditionally, a “Risk of
Chemicals” has been defined to exist when a product utilizes a consumable chemical which is considered
hazardous to the user. For product safety standards, this is the extent of the definition. However, chemical
content in product components is a growing concern in a number of international countries (i.e. EU/CE – RoHS
II). And although component chemical content is not part of the Risk of Chemicals definition in the UL/CSA
product safety standards, we have included consideration for international compliance purposes (as well as for
child products in the US).
Risk of Chemicals – Product Considerations: We have two areas of consideration with Risk of Chemicals:
- Chemical Consumables such as ink in a printer, scented oils in a room freshener, cleaning solution in floor
polishers, or a chemical being analyzed in lab measuring equipment. Consumable chemical ingredients when found in products should be non-hazardous to the user regardless of exposure time.
- Chemical Content concerns are now a big consideration for electrical products in addition to child products.
Limiting the % of content from numerous controlled and banned substances is becoming a major part of
regulatory compliance. Chemical Content concerns include substances such as lead in solder, BPA and phthalates in plastics, and cadmium in metals.
Risk of Chemicals – The Requirements:
- Product Safety Standards: The product safety standards (UL, CSA, EN, IEC) typically only address Chemical Consumables used with a product when reviewing for Risk of Chemical Hazards. Be sure to
obtain and review the MSDS (Material Safety Data Sheet) for all consumable chemicals to determine the
recommended uses and exposure levels.
- Laws on Chemical Content: Chemical content hazards of materials are not included in the product safety
standards. Rather, they are typically addressed through governmental regulations and mandates. This
includes US-CPSC requirements for child products, California Prop 65 requirements, EU REACH, and EU-
CE RoHS II requirements. Other countries are also adding similar regulations such as China RoHS 2.
Risk of Chemicals – Summary: It is rapidly becoming important that product manufacturers know the complete
content of their products, down to the smallest ingredient. While manufacturers of Chemical Consumables are
experienced with documenting hazards and informing the user through MSDS sheets, how many people read
them? In addition, suppliers have been found to be substituting ingredients making it difficult to trust the vendor.
And considering that chemical content is something you cannot “see”, the compliance process can be difficult.
Compliance Assistance Services to help you get it right the 1st time
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