“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 #4 – Risk of Injury.
Risk of Injury Definition: The 4th hazard is perhaps the easiest to conceptually understand. A “Risk of Injury”
exists when the user has access to a mechanical hazard = moving parts, pinch points, sharp edges, instability,
etc. Mechanical hazards that are necessary for the proper operation of the product must be suitably guarded
with additional warning markings and instructions. Otherwise, mechanical hazards must be protected to prevent
Risk of Injury – Consumer Products: For consumer products, mechanical hazards are generally limited to easy
to identify and resolve issues. Low risk injury hazards in products used in North America are addressed by UL &
CSA standards. In the European Union, low risk injury hazards are addressed within the EN standards listed
under the CE-Low Voltage Directive.
- Sharp edges and pinch points are obvious concerns to address. When in doubt, subjective decisions can
be made using devices such as the UL “sharp edge tester” or the “sharp point tester” for toys.
- For larger products, tip-over and push-over concerns apply. In addition, products with a horizontal surface
that could be misused as a step are force tested to insure they do not lose stability when misused in this
manner. Products with integral seating are tested to insure that when someone sits on the edge, the
product does not become unstable.
- The biggest potential for injury is with access to hazardous moving parts. For most consumer products,
this is usually the moving parts of a motor or fan in an appliance or tool. For this reason, product safety
standards for products that typically contain motors include additional requirements for protection from
moving injury hazards.
Risk of Injury – Large Scale Industrial Products: Large scale industrial products (i.e. factory equipment) are much
more likely to contain parts involving a risk of serious injury = products that perform smashing, grabbing, bending,
forming or other actions that could cause loss of limb or life to the user as well as others in the vicinity of the
equipment. More serious hazardous moving parts in the U.S. are addressed by OSHA requirements. In the
European Union, high risk injury hazards are addressed by the CE-Machinery Directive.
Risk of Injury – Summary: From an overall hazard consideration, the question becomes, what level of risk is
involved with the injury hazards for the product in question. For most consumer products, the mechanical hazards
are low risk and covered by the UL/CSA/EN/IEC product safety standards. For large-scale industrial products
with serious injury concerns, additional requirements include OSHA laws in the U.S. and the CE-Machinery
Directive in the EU.
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