What is a “reasonable testing program” as it pertains to general conformity certification?
A9: General Conformity Certification (GCC) does not mandate third-party testing. It can be based on a test of each product or upon a “reasonable testing program. The CPSC states that a “reasonable testing program” does not require third-party testing; can be based on XRF technology, if that technology is used in a reliable manner; and, if the manufacturer is confident in the results of lead tests done on components, does not necessarily require tests of the final product. With a GCC, you are certifying that your product meets regulatory compliance, so if you feel your test program provides you with the confidence to certify your product, that is acceptable. While the CPSC has not yet clearly defined “reasonable testing program,” The Toy Industry Association (TIA) has developed its own voluntary Toy Safety Certification ProgramSM which includes parameters such as sample size, sample selection, and frequency of testing. The TIA program also requires a design hazard and risk assessment as
