In this first podcast, Gail Greatorex of Product Safety Solutions talks to long-time product safety practitioner and champion Mr Gene Rider of Rider Technologies, USA.
This is a valuable resource for anyone trying to understand how product safety works!
In the interview, Gene explains what is an effective approach to product safety and how companies can meet the challenges. He draws a key distinction between product quality and safety and discusses the importance of designing safety into products.
Gene lists four key steps to eliminating hazards from products
Gail: Gene, can I start by asking you how long you’ve been working in product safety and what you enjoy about it?
Gene: A little less than 35 years and it’s been a very interesting experience. The most interesting thing about being in the business of product safety is you’re doing something that’s measureable and has a societal benefit.
For those 35 years, we actually ran a business on a global basis and at the same time we reported our results in terms of injuries prevented. It adds a sense of importance and completeness to your life’s work.
In that sense, we were able to get a great deal of cooperation and energy for our global staff. We actually managed with passion management. And the passion was preventing injuries. That was the culture of the organisation.
At one point we had many hundreds of people around the world, including China who were working on projects. Everybody was about preventing injuries, although it was a commercial business and enterprise.
The challenge and costs of compliance
Gail: What do you think are some of the greatest challenges for business in complying with product safety regulations?
Gene: I want to take a few seconds to talk about that. Number one is: when we think about consumer product regulations, there’s one overarching regulation and that is that products have to be safe. Whether a product complies or doesn’t comply with bans or standards, it still has to be safe.
The confusion is there is a whole bunch of legislative standards and voluntary standards out there that a company strives to learn about, understand and implement, but it doesn’t mean their product is safe. It only means their products are not violative with a standard.
So, it’s a two-step process. The first step is to know what markets your product is going to go into, then know what the standards are for the product category in those markets.
The second step is an overarching one for all markets. That is make sure your product is essentially safe. It’s two very different, distinct challenges.
Learning those regulations used to be easy. Ten years ago we would have 30 new regulations globally that covered most consumer goods. Now it’s more like 700 a year. It’s a 20-fold increase in the number of regulations. The differences are dramatic. Sorting through the regulations and how to demonstrate compliance through a robust but relatively simple testing or certification program – it becomes quite tricky.
Gail: And companies are on a better footing if they are already attempting to make all of their products safe.
Gene: Essential safety should be the overarching umbrella for the product. You take it to that level and then you know you won’t have the recalls, the injuries or injury complaints.
‘Safety and quality are twin sisters’
Gail: Some companies say that making their products safe and compliant with regulations costs too much? What do you say to them?
Gene: I say that could be the case for them. But it’s proven that if you have a robust safety and quality program – I want to explain that safety and quality are twin sisters. Most of the things we do in safety are using quality tools. We use tools that have been around for more than 100 years. It’s the way we measure the performance of the product.
Gail: So, the tools that apply to quality will also apply to safety?
Gene: Correct, those are the ones we use. I call them the twin sisters. If you have a robust safety quality program and you implement that program across your product lines, there are some very very important benefits that come out of that. Besides not having injuries, complaints or recalls, you actually enable innovation. It’s stunning how much you enable innovation. You reduce product cost because you don’t have to re-work or issues with poor quality products. You do also increase speed to market. These are proven things that happen when you have a robust program.
Gail: Perhaps if we could talk a little bit about the internet and how it’s impacting product safety. Some good ways, some bad ways. We might even describe them as opportunities and threats. Could you describe an example from your perspective?
Gene: I don’t see the internet as either an opportunity or as a threat except for one thing – information. On the internet, we can get a huge amount of information about injuries, safety, processes, what other people do, research reports being immediately available to us on the internet and for free. We can really understand hazards and the characteristics of products that are hazardous.
Gail: And that’s a resource for suppliers.
Gene: That’s a huge resource that we’ve never had before. The challenge is there is a lot of misinformation on the internet. We’re just going through an OECD project with a demonstration on button-cell batteries and the hazard of when they’re swallowed by a child or by someone and it gets stuck in the oesophagus. If you went back to the internet 15 years ago, you would find a lot of misinformation about how safe those button-cell batteries were. That’s unfortunate because people were severely misled. I say the opportunity is to get the information that would not immediately have been available so quickly. But you have to verify the information you have. You have to have multiple sources and make sure that it makes sense.
Gail: I believe Google has shifted its search engine operation so that it favours more of the authoritative sources now than it used to do.
Gene: I think that’s true, but they do switch their algorithms often so we never know where it’s going.
‘75% or more of all recalls and injuries from consumer products are the result of design defects.’
Gail: One of the best ways to ensure product safety is to design the safety into the product from the outset. That is, to look for ways to eliminate any hazard at the design stage. It’s much better to do that than rely on consumer warnings of course. Could you tell us a bit about that and do you have any particular examples of where hazards have been eliminated in the design stage?
Gene: Let me address that quickly. The first thing is that you’re absolutely correct. 75% or more of all recalls and injuries from consumer products are the result of design defects.
When you have a design defect, it means 100% of your product is defective. When you have a production or manufacturing defect, it doesn’t always mean 100%. Many times it’s a much smaller percentage.
Design defects and eliminating them has got to be the primary job of a safety process.
There’s four steps that are key to that. You have to be organised to do them because it’s a multi-disciplinary approach. It’s not often you find someone who knows how to do all four things, on a complicated product at least.
One: Injury data analysis – You have access to injury data and you have to think about the data differently than many people do. That is – it is not a product type that results in an injury, but the characteristics or features of the product that results in the injury.
When you’re looking at the injury data, the thing you look for are the characteristics in the product that resulted in the injury.
You also want to know the behaviour of the victim of that injury. If it was a child or an elderly person, or someone who should have been cared for, what was the behaviour of the carer that resulted in the injury. You also can gain from that the severity of the injury and what body part was involved.
Those are the five most important things you can get out of injury analysis. It is absolutely essential you learn from the mistakes of others. And where you find that is in the injury data. Access injury data, no matter how difficult it is to get to it, is essential to start processing a good design.
Two: Foreseeable use – predicting how the product will be used. It’s not how you intend it to be used; it’s predicting how the product is going to be used.
If you know how the product will be used, you can then decide what characteristics would be hazardous and also decide what features are causing it to be used that way. You have an option to mitigate the hazard and change features that create the foreseeable use that are unsafe.
Gail: That sort of thinking is important to do at the start of the product design process.
Gene: Absolutely. 30 years ago you couldn’t predict foreseeable use. That is not true now. Children go through a predictable and known process of learning and they have fifteen clear strategies they use in the process of learning. You can do a great job predicting how they’ll use a product based on its features.
Gail: Even the age grading guidelines that are available for toy characteristics go through some of those development phases. That’s available online.
Gene: We also have a new ISO guide 50 available that has some interesting information.
Three: Human factors – The third thing is what we call human factors. It is understanding the physiology of the user of the product and their strength characteristics. The physiology is about size, how things fit, where will they go, can they cause choking etc.
Beyond that, what is the user’s strength? We have standards out there saying something can withstand this many pounds or this much torque, but the reality is that products aren’t used the way the standards are written. It’s important to understand what the user such as a child can do and how he will do it and make sure that won’t result in a hazardous part.
Four: Control points in manufacture – Finally, in the manufacturing process you always have critical control points. They’re things you need to control. You learn about those when you design products because if this piece breaks, or this piece moves in that direction, or this hinge works this way then this will cause a hazard. While doing the design, you also define the critical control points and pass the design as well as the critical control points on to the manufacturer. That way, you can be assured the product will be made the way it has been designed to be safe.
‘It’s fascinating what we were able to accomplish by using that robust program.’
Gail: That’s an excellent explanation of those points in relation to design. Do you have any examples you can tell us about?
Gene: We have thousands of examples because we’ve worked on thousands of products where we have started the design the moment the inventor started to think about the product.
I had staff when I was with Intertek who were working on the Happymeal toys. Every Happymeal toy went through a design standard. Those four steps I just defined were used on every toy. What’s fascinating is that while billions of toys were distributed annually, the injury rates with those were three orders of magnitude less than any other toys on the market. It’s fascinating what we were able to accomplish by using that robust program.
Gail: Taking the design element into account at the outset – that’s very reassuring.
Who has responsibility for product safety?
Gail: Changing subjects, it seems to me there’s often debate about who is the most responsible for safety of consumer products. Is it the government, consumers, suppliers or all of the above? Where do you think the responsibility lies?
Gene: Generally it’s not the consumer. Certainly it’s not the young consumer. The young consumer is driven to explore his environment and himself simultaneously. They’re driven to take risks.
In terms of the consumer, some will do some dumb things and you can’t always prevent that.
Governments are there to enforce safety regulations and that’s what they do. They’re like a traffic cop. What they can do is provide infrastructure, information, injury databases, education on processes that work, best practices, etc. They can give a helping hand to manufacturers and designers who want to make safe products.
The bottom line is that it’s up to the inventor, manufacturer and person putting the product on the market (the economic operator) to make sure they have a safe product. That’s where the safety has to lie.
Gail: Yes, I believe that’s the case. In terms of the individual sectors, what do you think people can do to fulfil their own responsibility?
Gene: People have to be alert to potential hazards. The internet helps because people can learn about other people’s experiences with products. It doesn’t hurt to learn things.
An interesting experience for me has been the safety manuals that come with tools and automobiles. I find that when I ask a group of people ‘how many of you have a car?’, and I ask ‘how many of you read the manual?’ and no-one has read the manual after they bought their first car.
But when they buy something very different they’ll often go back and read the manual. One of things that would be helpful is if the consumer goes back and reads the manual (and if the manuals were written better).
There are new characteristics and features to these products as we buy them and reading the manual helps understand what others have learned what hazards there can be.
Gail: I bought a car a few years ago that had airbags, which I hadn’t had before. I did read the manual. One thing I didn’t think of is that you have to grip the steering wheel a little differently. If you wrap your thumbs around the wheel, the airbag will potentially impact your thumbs badly.
I told a friend this and he said ‘I’m not going to worry about it. If my airbag goes off the last thing I’ll have to worry about is my thumbs being broken.’
I’m not sure if that’s true because an airbag could go off and you would be otherwise uninjured and that’s why they’re there. If you had two broken thumbs when it’s avoidable, I’m not sure that’s the best way to go.
Gene: That’s an excellent example. Years ago when they came out with the passenger-side airbag, we learned that we couldn’t put small females and young children in the passenger seat. Now we can because they fixed that problem. Reading the manual is helpful. Taking training frequently is helpful. Online there are great programs, including for drivers.
Gail: Companies can put up videos and other advice. Hopefully that will continue to evolve. Even some interactive things so that people learn while they’re going about how to use their products properly.
One of the other key resources for consumers is to monitor recalls. It’s easy to register or subscribe to recall databases so you get a notification when any product is recalled.
It’s also a vital resource for the suppliers because if a product is similar to one they’re producing is recalled, then they need to know about that for several reasons.
It could happen to them and the bad publicity could impact their own product – people will have doubts about them as well. It’s a learning opportunity for everyone to follow product recalls.
Gene: Once again the internet gives us information.
How to identify hazards
Gail: We all know some product hazards are obvious such as matches and knives, but in many products the hazards are less obvious. Can you tell us about a hazard that was difficult for a consumer to recognize, that you’ve maybe worked on?
Gene: This is an interesting question. One of the reasons product hazards are less obvious is because people don’t understand foreseeable use. The product users don’t understand intended use and don’t understand they might be using the product the way it wasn’t intended to be used. I still don’t believe it’s their fault. The product should be made in a way people will foreseeably use it but I think that’s one of the challenges.
The hazard is not obvious. One example is the window blind cords and infants. It’s not an obvious hazard. It is a rare but catastrophic event.
Gail: Can you explain the hazard?
Gene: Window blinds often have a cord for raising or lowering them or changing the degree of openness. What happens is if they’re in the nursery, children sometimes get them wrapped around their necks and because of the children’s inability to remove themselves from this, we have some strangulations. It’s a rare event. Most parents don’t understand that that can happen.
Another incident is when people buy a baby bath seat. Even though the bath seat seems to stick to the tub and can’t be removed. They don’t understand that it can be removed. Most of the baby’s mass is above its hips. Because it is above its hips, the baby doesn’t sit in the seat very well. It will slide out of that seat. And babies drown in just a little bit of water. Many times parents will leave the baby unattended for a few minutes, which results in a catastrophic event. These hazards are unexpected.
Gail: What lessons might there be for product designers in working out what these unexpected hazards are?
Gene: That becomes a challenge for the designer but comes back to the injury data analysis. If you’re making a window blind and you know it’ll end up in a nursery, you might want to think of an alternative to a cord. There are patented designs out there for window blinds without cords.
When you’re thinking of bathing a child, you might want to think about a completely different device – maybe not for use in the tub. Something that forces the carer to stay with the baby and has minimum amount of water and eliminates possibility the child drowning. The seat position will be important because of the high mass above its hips.
Gail: So thinking about the way hazards can occur, and trying to eliminate those by designing the product in a different way.
The other thing that goes along with the product design is marketing. If the marketers don’t talk to the designers and then try to convey that the product is capable of more things than it is able to be. Or even just the name of the product . . .
Mentioning bath seats, I know that in Australia we’ve had a bath seat by a brand or model called ‘Safety First’. That adds to people’s perception that they can use it as a safety product and leave the bathroom with the child unattended.
Gene: That’s an excellent point. Keep in mind that marketing can teach people to do bad things with products. Sometimes marketing will show someone using the product in a hazardous way that would not have been foreseeable. The child or user would not have thought about.
Gail: And the designer wouldn’t have envisaged it either.
Gene: There has to be a good cooperation between the marketing message and the actual design of the product.
Gail: This has been an excellent interview, Gene. I appreciate you taking some time. Do you have any interesting anecdotes to finish on? Strange products, curious supplier attitudes, any stories?
Gene: I think we have plenty of stories. One of the things designers, manufacturers and distributors don’t really realise is at the factory level – many times they’re using products/raw materials and they don’t know what’s in them. They have a solvent and don’t know what its characteristics are. They may run out of one raw material and substitute another one and that can destroy the robustness of the design.
What I would say is that when I think of the manufacturing defects, most of them come from substitution.
The challenges I see in factories where they spend a lot of money on ink and paint without heavy metals. Because of the way they’ve managed the machines, they end up mixing paint or ink containing heavy metals with the good stuff. Then we end up with products that fail the standards. There’s a lot of opportunity there to train our suppliers, know who they are, and make sure they have good control of the factory and materials.
Gail: Let’s wrap it up there Gene. Thank you.
Gene: Thank you for inviting me, I’ve enjoyed this.
This interview was recorded in Brussels, Belgium, June 2014.
From 2016 Gene is now a principal consultant at Exponent.
Exponent is a consulting firm that brings together more than 90 different disciplines to serve needs in engineering, science, business and regulation. It has offices across the USA as well as in Asia and Europe.