International

• Australia
• United States
• Canada
• Europe

14. In assessing the options available for addressing the safety issues, the Ministry is expected to take into account the wider perspective of government and the global environment in which trade takes place.

15. Interventions that act as trade barriers have to be avoided. Nevertheless, a commitment to free trade has to be balanced by the need to ensure that consumer safety is not compromised.

Australia

16. Dummies/pacifiers considered children's nursery products would accord with the Australian approach, although at present Australia does not mandate the small part requirement for dummies/pacifiers.

United States

17. The US Consumer Product Safety Commission (CPSC) has regulation for pacifiers Requirements for Pacifiers, 16 C.F.R. Part 1511 (January, 2001).

18.

"The rule requires that:

• the shield not be so small or flexible that it can be sucked into a child's mouth;
• the a pacifier have no handles or other protrusions, that are long enough to force the pacifier into the child's mouth if the child falls or lies on its face;
• pacifiers are labeled to warn caregivers not to tie the pacifier around the child's neck.
• a pacifier not produce small parts when tested."

Requirements for Pacifiers, 16 C.F.R. Part 1511 (January, 2001)

19. The American mandatory standard does not cover the chemical hazards associated with dummies/pacifiers. The CPSC recommends ASTM F963-03 Standard Consumer Safety Specification for Toy Safety and ASTM F1313-90(1999) Standard Specification for Volatile N-Nitrosamine Levels in Rubber Nipples on Pacifiers for this purpose.

20. The CPSC website highlights the frequency of product recalls for pacifiers and has logged 5 recalls for pacifiers in 2005.

Canada

21. Health Canada has regulation for pacifiers under the Hazardous Products Act, Hazardous Products (Pacifiers) Regulations 1991 which covers toxicity, design and construction tests, and includes the small part requirement.

Europe

22. Europe Union has a General Product Safety Directive (2001/95/EC) which imposes a general requirement on manufacturers and suppliers etc not to place a product on the market unless it is safe. Manufacturers must take all reasonable efforts to ensure their product is safe. Compliance with voluntary national standards is deemed to meet the general safety requirement.