LEGISLATION CALLS UP the standards

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Australian legislation specifies 9 standards for the assessment of products continaing button batteries. (a)  the Australian (Audio/Video) Standard; 

(b)  the Australian (Electric Toys) Standard; 

(c)  the Australian (Safety of Toys) Standard; 

(d)  the Electronic Apparatus Standard; 

(e)  the International (Audio/Video) Standard; 

(f)  the International (Electric Toys) Standard; 

(g)  the International (Safety of Toys) Standard; 

(h)  the Lithium Technologies Standard; 

(i)  the Luminaires Standard.

With so many standards referenced by the legislation, we can expect a messy train-wreck of competing product approvals and general confusion across Australian importers and manufacturers. On this page, and others, I try to clear it all up.

For the purposes of this blog we will ignore the standards relating to Toys.

Each standard is different. However the elements of the standards called up by the legislation share commonalities, while other aspects are unique.

TOOLS OR INDEPENDANT HAND MOVEMENTS

This is the first hurdle. All the standards have a requirement that a tool is required to gain access to the battery compartment.  However, and this is important, Australian legislation does NOT call up this requirement in each standard, only some.

Tool access can be anything such as a screwdriver, coin or pliers. The alternative test is that two independant and simultaneous hand movements are required. The most common product that uses this method are medicine bottles. Other examples can be seen in our blog. Remember, this hurdle does not apply if a tool is required to open the battery compartment.

CAPTIVE SCREWS

Some standards require the use of captive screws. These are the screws that stay in place when you undo them, and are quite handy becuase you can't drop them. The idea behind this is that you are not likely to lose the screws and leave an unsecured remote lying around the house.  Once again, the Aussie legislation does not call up this requirement for each standard, only some.

TORTURE TESTING

All bar one of the standards call up a rigorous sequance of testing. In summary

• Heat the product for 7 hours to weaken the plastic
• Torque up the screws repeatedly
• Open and close repeatedly
• Drop on hard surface up to 10 times
• Smash it with a steel ball 3 times
• Crush it with a significant force
• Use a probe to pop off the battery cover

There is no requirement for torture testing in the Luminaires standard!

Some standards are almost duplicates of each other, so there is no point getting bogged down with all 9 of them. I have simply summarised them in to 3 categories and given them a BBL Reference or nickname.

Where it applies to a Standard as outlined in the table below, the primary elements of the various hurdles are the same.  For example, the requirement to use a tool (or simultaneous hand movements) share very similar language. Similarly, the tortures tests are almost the same across those standards where it applies.

The legislation does not specify which standard should be used to assess your product. So in a strictly legal sense, it appears you could use the Toys Standard to assess a car key. However, I wouldn't want to be on the wrong end of litigation if I had sold a car key that killed a baby and I had used the Toys standard to assess the product.

In any case, each standard does give an overview of its intended purpose. For example, the Luminaires Standard states... "the objective of this Standard is to specify general requirements for luminaires, incorporating electric light sources, for operation from supply voltages up tp 1000V".  So it would be a bit weird to use that Standard for a remote control.

The authors of the Luminaires standard did not think it appropriate to crush the products in a vice and drop from heights and other torture tests that are common to the other standards. It is just not the sort of normal treatment you would reasonably expect a lighting product to endure in the normal course of use. Car keys and garage remotes, on the other hand, are regularly dropped and stood on and goodness knows what else. So to use the Luminaires standard to assess a car key might be legal in the strictest sense, I reckon it could really bite you in the backside later.

So let's put the Luminaires standard to the side for now. So that leaves...

1) American UL Lithium Standard, or 

2) the group of AV Electronic Standards.

These 2 options share the same (or very similar) requirements for torture testing. The big difference is that the Australian legislation, where it calls up the American UL Lithium Standard, does not call up Section 5 [Construction]. So the burden of 'tool required for access' (UL Section 5.5 (a)) is removed. 

On the other hand, where the legislation calls up the Australian AV Electronic standard, it does call up  Section 4.8.3 [Construction]. This does impose the 'tool required for access' burden.

So rather then use the Australian AV Electronic standard, which instantly fails all flip keys that do not need a tool to open, it makes more sense to use the American UL Lithium Standard. This is a more balanced and fair assessment, and is discussed at length in the blog "The Flip Key Conundrum"