Multi-Purpose Lighters Video Transcript

Slide 1 - Cover page


Slide 2 - Introduction

  • Hello, my name is Matthew Lee, and I’m a Compliance Officer in the Office of Compliance and Field Operations at the U.S. Consumer Product Safety Commission (CPSC).
  • Today, I’ll be explaining U.S. requirements for multi-purpose lighters that manufacturers and importers must meet if they import or distribute multi-purpose lighters in the U.S. market.
  • Requirements for multi-purpose lighters, also known as the Safety Standard for Multi-Purpose Lighters, Title 16, Code of Federal Regulations, Part 1212 [16 C.F.R. Part 1212] are published in the Federal Register.


Slide 3 - Topics of Discussion

In this presentation, I’ll cover the following topics:

  • Purpose of the Safety Standard
  • Scope of the Safety Standard
  • Definition of Multi-Purpose Lighters
  • Requirements for Multi-Purpose Lighters
  • Qualification Testing
  • Production Testing
  • Recordkeeping and Reporting
  • Labeling Requirements
  • Certification Requirements


Slide 4 & 5 - Purpose of the Safety Standard

  • The Commission’s hazard data demonstrate that lighters covered by the standard pose an unreasonable risk of death and injury to consumers if they do not comply with the standard.
  • The purpose of the safety standard is to address the unreasonable risk of injury and death associated with multi-purpose lighters that can be operated by children under age 5 years.
  • The Safety Standard for Multi-purpose Lighters took effect for products manufactured or imported after December 22, 2000.


Slide 6 - Scope of the Safety Standard

  • The rule, Title 16, Code of Federal Regulations, Part 1212, prescribes requirements for multi-purpose lighters.
  • Multi-purpose lighters subject to 16 C.F.R. §1212 include but are not limited to the following:
  • Grill lighters, fireplace lighters, utility lighters, gas match lighters, and micro-torches, and
  • Are manufactured in the United States, or imported, on or after December 22, 2000.


Slide 7 - Definition of Multi-Purpose Lighters

As defined by 16 C.F.R. §1212.2 (a), multi-purpose lighters are:

  • Hand-held,
  • Flame-producing products that
  • Operate on 10-oz or less of fuel.
  • Have an ignition mechanism that is part of the lighter, and
  • Are used by consumers to light items such as candles, charcoal, campfires and stoves, fuel-fired appliances and pilot lights.
  • They may also be used for brazing or soldering.


Slide 8 - Definition of Multi-Purpose Lighters

  • However, cigarette lighters and matches are not multi-purpose lighters.
  • Lighters containing more than 10 ounces of fuel are NOT subject to the Safety Standard for Multi-Purpose Lighters.


Slide 9, 10, 11 & 12 - Multi-Purpose Lighter Examples

  • Here are some examples of multi-purpose lighters.


Slide 13 - Requirements for Multi-Purpose Lighters

  • Now what are the requirements for multi-purpose lighters?
  • First, at least 85% of the children who test a surrogate multi-purpose lighter as described in the Test Protocol must not be able to successfully operate the lighter.


Slide 14 - Requirements for Multi-Purpose Lighters - 16 C.F.R. §1212.3

  • Second, the child-resistant mechanism of a multi-purpose lighter must also:
    • Operate safely when used in a normal and convenient manner.
    • Work properly for the reasonably expected life of the lighter.
    • Must not be easy to deactivate or override, and
    • Must automatically reset when or before the user lets go of the lighter.


Slide 15 - Requirements for Multi-Purpose Lighters - 16 C.F.R. §1212.3

  • If a multi-purpose lighter allows hands-free operation, then it must also have an additional feature that locks the flame on. In other words, it must have a manual mechanism (e.g., lock, switch, etc.) for turning on the hands-free function after the flame is lit.
  • In addition, the child-resistant feature on such a lighter must automatically reset after the flame is turned off.


Slide 16 - Qualification Testing

  • Before any manufacturer or importer distributes lighters in the U.S., surrogate lighters of each model must be tested in accordance with the Test Protocol at 16 C.F.R. §1212.4 to ensure that all such lighters comply with the safety standard.
  • If a manufacturer has tested one model of lighter, and then wishes to distribute another model of lighter that differs from the first model only by differences that would not have an adverse effect on child resistance, the second model need not be tested in accordance with the Test Protocol.
  • However, it must still be reported to CPSC.
  • The test procedure for Qualification Test is described in detail in 16, C.F.R. Part 1212.4.

Slide 17 - Qualification Testing

  • The qualification test uses at least one, but no more than two, test panels of 100 children between the age of 42 and 51 months to test surrogate lighters.
  • Each panel is divided into 3 groups - about 30 children 42 through 44 months old, about 40 children 45 through 48 months old, and about 30 children 49 through 51 months old.
  • Approximately two thirds of the children in each group must be boys.
  • The test procedure allows only a small variation in the size of each group and in the number of boys and girls in each group.
  • Each child in the test panel must live within the United States,
  • Each child has no illness, injury, or disability that would interfere with the child’s ability to operate the test lighters.
  • Before any child participates in a test, a parent or legal guardian must fully understand that they are being asked to allow their child to be tested, and sign their name to agree in writing to let the child participate.


Slide 18 - Qualification Testing

  • For the Qualification Test, surrogate lighters used.
  • What is a surrogate lighter?
    • A surrogate lighter is a substitute for an actual working lighter. Surrogate lighters are used so that children do not have to operate real lighters.
    • A surrogate lighter approximates the appearance, size, weight, and shape of an actual lighter intended for use by consumers.
    • It does not have fuel, and
    • It must also be identical to the actual lighter in all characteristics that might affect child resistance, including the method of operation and the force(s) and displacement needed to operate the lighter.


Slide 19 - Qualification Testing

  • Before any lighters subject to the standard are distributed in the U.S. market, manufacturers and importers should make sure that the surrogate lighters used for qualification testing are described in a written product specification.
  • The product specification should include the following information:
  • All operating characteristics of the surrogates must be measured and recorded before and after the child-panel test.
  • Critical operating characteristics include, but not limited to:
    • The force and displacement required to move a component
    • The manufacturing tolerances
    • Any other components that could affect child resistance.


Slide 20 - Qualification Testing

  • Every detail of the test is specified in the test protocol:
    • The number of boys and girls in each age group tested;
    • The number of surrogates, testers and test sites;
    • How many children may be tested at each site;
    • How many children a tester may test;
    • How many children must test each surrogate; and
    • Exactly what is said to the children during the test.
  • This is done to make sure that all lighters are tested the same way, and that the results are as accurate as possible. Review the protocol carefully to make sure that you comply with all of the testing requirements. You are responsible for ensuring that firms that test your lighters fully comply with the protocol.


Slide 21 - Qualification Testing

  • Two children at a time participate in the test in a well-lighted room that is familiar to them or with which they are given time to become familiar and is free from distractions. A tester first operates a surrogate lighter in the presence of the children without letting them see what he or she is doing, so that they will know what signal the surrogate makes when it is operated successfully. The tester then places in each child’s hands a surrogate lighter, and asks the children to try to make the same sound or signal. Each child has five minutes to try to do this.
  • If a child succeeds in making the sound or signal, he or she is not tested further and that child’s test is counted as a successful operation of the lighter that the surrogate represents. The tester demonstrates to any child who does not succeed in the first five minutes. The child then has five more minutes to try to operate the surrogate successfully. Any child who succeeds in operating it in the second five minutes is also counted as a successful operation of the lighter. Any child who successfully operates the lighter in the first five minutes must remain until the other child has finished his or her test.
  • Any child who does not try to operate the surrogate must be eliminated from the panel and replaced by an eligible child.
  • For a lighter to pass, at least 85% of the children tested must be unable to operate the surrogate lighter. For the first 100-child test panel, if 10 or fewer children operate the surrogate successfully, the lighter that the surrogate represents passes. If 19 or more children succeed, the lighter shall be considered non-resistant. In either case, no further testing is necessary. If 11 through 18 children in the first panel operate the surrogate lighter successfully, a second 100-child panel is tested. In that case, the lighter shall be considered non-child-resistant if 31 or more of the total 200 children tested operate the surrogate successfully.


Slide 22 - Qualification Testing

  • A child may only participate in one cigarette lighter panel and one multi-purpose lighter panel in a lifetime.
  • No child may test more than one multi-purpose lighter.


Slide 23 - Production Testing

  • The surrogate lighter that has been shown to be child-resistant by qualification testing is required under 16 C.F.R. §1212.15 to meet certain specifications. Manufacturers and importers should test samples of lighters subject to the standard as they are manufactured to make sure that the lighters meet these specifications.
  • Manufacturers and importers should also make sure that each production test be conducted at a production interval short enough to provide a high degree of assurance that all other lighters produced during the interval meet the standard.
  • If any test results indicate that any lighters in a production interval may not meet the standard, the lighters should not be produced or distributed in the U.S. market until corrective action is taken.
  • In addition, production test records (including the test method, procedures, interval, sampling scheme, pass/reject criterion, etc.) and results must be in English and kept in the United States.


Slide 24 - Recordkeeping and Reporting

  • Records of qualification testing, including, a description of the tests, photograph(s) or a video tape for a single pair of children from each test panel, the dates of the tests, the data, the actual surrogate lighters tested, and the results of the tests.
  • Records of procedures used for production testing, including a description of the types of tests, the production interval selected, the sampling scheme, and the pass/reject criterion.
  • Records of production testing, including the test results, the date and location of testing, and records of corrective actions taken.
  • Records of the lighter’s production specification


Slide 25 - Recordkeeping and Reporting

  • All records of qualification testing, production testing procedures and specifications must be kept for three years after production ceases.
  • Records of production testing including testing results should be kept for three years after the date of the testing.
  • Such records must be kept in the United States and provided within 48 hours to any designated officer or employee of the Commission who asks for them. However if a lighter is not manufactured in the U.S., qualification testing, and production testing records may be kept outside the United States.


Slide 26 - Recordkeeping and Reporting

  • In addition, at least 30 days before ANY manufacturer or importer imports into or distributes in the United States any model of lighter subject to the standard, the manufacturer or importer must provide a written report to the Office of Compliance that includes:


Slide 27 - Recordkeeping and Reporting

  • First, the name, address, and principal place of business of the manufacturer or importer.
  • Second, a detailed description of the lighter model to be imported or distributed and of the child-resistant feature(s) used on the model.
  • Third, a description of the testing done to establish that the lighter is child resistant, including a description of the surrogate lighter tested, the specifications for the surrogate lighter, a summary of the results of all such tests, the dates the tests were performed, the location(s) of such tests, and the identity of the organization that conducted the tests,
  • Fourth, an identification of the place or places that the lighters were or will be manufactured.
  • Fifth, the location(s) where the records of testing of the lighter are kept,
  • Sixth, a prototype or production sample of the lighter model for which the lighter information is submitted.


Slide 28 - Recordkeeping and Reporting

  • And written specifications which must be kept for any component that may affect child resistance. The written specifications include, but not limited to:
    • Force and displacement requirements
    • Manufacturing tolerances
    • Size, shape and dimensions
    • Any other information or features that may affect child resistance
  • Submission reports must also include:
    • Copies of informed consent forms and test records for each child
    • All surrogate lighters and 3 production samples


Slide 29 - Recordkeeping and Reporting

The report should be sent to:
Lighters
U.S. Consumer Product Safety Commission
Office of Compliance and Field Operations
4330 East West Highway
Bethesda, MD 20814-4408


Slide 30 - Recordkeeping and Reporting

  • CPSC’s Office of Compliance and Office of Hazard Identification and Reduction consider that successful submission reports typically include:
  • Pre- and post-test measurements of all features that affect operation of the surrogates,
  • How the measurements were made.


Slide 31 - Recordkeeping and Reporting

  • Submission reports should avoid
    • Measurements of the surrogates are missing or incomplete
    • Specifications for production lighters missing or incomplete
    • Production specifications differ from measurements of the surrogates
    • The lighter’s child-resistant features are inaccurately described
    • Child test procedures are incorrect
    • Informed consent forms and data records are missing


Slide 32 - Labeling Requirements

  • The manufacturer or importer must label each multi-purpose lighter with the following information, which may be in code:
  • Identification of the period of time, not to exceed 31 days, during which the multi-purpose lighter was manufactured.
  • Identification of the manufacturer of the multi-purpose lighter, unless the multi-purpose lighter bears a private label. If the multi-purpose lighter bears a private label, it shall bear a code mark or other label that will permit the seller of the multi-purpose lighter to identify the manufacturer to the purchaser upon request.


Slide 33 - Labeling Requirements

  • In addition, most multi-purpose lighters also meet the definition of a hazardous substance and are subject to the cautionary labeling requirements of the Federal Hazardous Substances Act (FHSA):
  • “DANGER-EXTREMENTLY FLAMMABLE. CONTENTS UNDER PRESSURE. Contains flammable gas under pressure. Do not use near sparks or open flame. Do not puncture or incinerate container or store at temperatures above 120°F. Keep out of the reach of children.”

Slide 34 - Labeling Requirements

  • The FHSA requires that the above text on the label should be in contrasting type, color, or layout to the other printed matter on the label. In addition, the FHSA requires the manufacturer, packer, distributor or seller name and place of business to be placed on the label of the product.
  • And the cautionary labeling must appear both on the lighter itself and on the retail display package and conform to the type, size, placement and conspicuousness requirements of 16 C.F.R. §1500.121. For more details, please see 16 C.F.R. §1500.3(b) (14), §1500.121 and §1500.130 for the specifics of labeling requirements.


Slide 35 - Certification Requirements

  • After conducting qualification tests on surrogate lighters, manufacturers and importers must certify that the lighters they sell comply with the standard.
  • A certificate must be based on a reasonable testing program of lighters sampled during production or on a test of each lighter produced for sale.
  • A reasonable testing program for lighters is one that demonstrates with a high degree of assurance that all lighters manufactured for sale or distributed in commerce will meet the requirements of the standard. Manufacturers and importers shall determine the types and frequency of testing for their own reasonable testing programs.
  • All reasonable testing programs shall include qualification tests, which must be performed on surrogates of each model of lighter produced, or to be produced, to demonstrate that the product is capable of passing the tests prescribed by the standard, and production tests, which must be performed during appropriate production intervals as long as the product is being manufactured.


Slide 36 - Certification Requirements

  • A certificate of compliance must accompany each shipping unit of the product (for example, a case) or otherwise be furnished to any distributor or retailer to whom the product is sold or delivered by the manufacturer, private labeler, or importer.
  • The Certificate of Compliance shall state:
  • That the lighter "complies with the Consumer Product Safety Standard for Multi-Purpose Lighters (16 CFR §1212)"
  • The name and address of the manufacturer or importer issuing the certificate or the private labeler, and
  • The date(s) of manufacture.


Slide 37 & 38 - Certification Requirements

  • In addition, manufacturers or importers must also comply with the General Certification of Conformity (GCC) requirement as stipulated in the Consumer Product Safety Improvement Act of 2008 (‘‘CPSIA’’) (16 C.F.R. §1110.11).
  • The GCC certificate should:
  • Describe the product covered by this certification in enough detail to match the certificate to each product it covers and no other;
  • Identify separately each rule, ban, standard or regulation under the Acts administered by the Commission that is applicable to the product;


Slide 39 - Sign-off

  • This concludes my presentation for the Safety Standard for Multi-purpose Lighters. If you have any questions, please feel free to contact me at MLee@cpsc.gov.
  • Thank you.