NCHR Comment on CPSC Proposed Investigation of Smart Toys and Additional Toys Through Child Observations Response
Docket No. 2023-0031
January 2, 2024
We appreciate the opportunity to again comment on the CPSC’s proposal regarding: “Investigation of Smart Toys and Additional Toys Through Child Observations.”
The National Center for Health Research (NCHR) is a nonprofit think tank that conducts, analyzes, and scrutinizes research on a range of health issues, with a particular focus on which prevention strategies and products are most appropriate for which patients and consumers. We do not accept funding from companies that make products that are the subject of our work, so we have no conflicts of interest.
We were surprised to learn that we provided the only public comment to the previous docket, and wish to revise our comment in response to the clarifications that the CPSC has provided in its revised request for public comments. As mentioned in our previous comment, we support the CPSC’s continued efforts to help ensure that toys and other consumer products are safe for use and are age-appropriate. We are pleased to learn that the CPSC is now specifying that “The proposed data collection is not intended to provide nationally representative data; this research is exploratory.” However, there are enormous differences in the range of abilities for children in this age group, and although CPSC states they have no intention of analyzing the data statistically, even preliminary exploratory research should be based on a representative sample of children and caregivers. If it is not possible to adequately represent a wide range of children’s social development, socio-economic status (SES), and social and cultural differences, then the CPSC should focus on including children who represent at least some diversity in terms of SES and social and cultural differences. Since the CPSC specifies that the nature of the exploratory study is to determine developmental differences in behavior between different age groups for appropriate age grading of toys in future CPSC guidelines, including a diverse group of children and caregivers is essential to help to make sure that the right questions are asked in this exploratory research to better inform subsequent study designs used to develop future guidelines for these toys.
With regards to the clarification of the number of toys that participants will interact with at each session, we hope that since each child will be introduced to 9 toys, there will be at least one toy from each of the 6 toy categories for each child. That would help determine how well children of specific ages and backgrounds play with toys in each of the 6 categories, so we hope that is what the CPSC meant when it said the study would introduce children to selected toys from the 6 toy categories.
We understand the need for the CPSC to prevent the potential overburdening of children in the study. Having more children in this exploratory study would help ensure more diversity while also helping to reduce the time burden on each child. This would ensure as much accuracy as possible in capturing the range of children’s responses to these 6 types of toys.
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