Health Canada and CPSC Release New Draft Guidance Document for Consumer Product Industry
On March 23, 2018, Health Canada and the U.S. Consumer Product Safety Commission jointly released a new draft guidance document titled Guidance on the Application of Human Factors to Consumer Products. The guideline sets out a number of significant proposed recommendations for how consumer product companies should “integrate human factors principles into the product development process”. The document is open for comment by industry until May 14, 2018 and will be of interest to companies involved in the design, development and manufacture of consumer products sold in Canada and the U.S.
A human factors-based approach to product development is one that considers and tests how people will use and interact with products, to ensure that products will perform and are safe for foreseeable uses and users. The draft guideline sets out Health Canada’s and CPSC’s perspective that a human factors-based approach to product design and development “is essential to achieve safe and effective products”.
The recommendations proposed by the guideline include that companies should:
- apply human factors principles at all stages of the product design and development process, and potentially engage a dedicated “human factors specialist”;
- consider and anticipate foreseeable “non-target” uses and users of products, to ensure that products are safe for all foreseeable uses and users even if they are not the “target” uses and users;
- evaluate and test products with “real world” users in “real world” use scenarios throughout the design and development process;
- recognize and account for diversity of ability and experience amongst foreseeable users, including use by vulnerable populations; and,
- apply human factors principles not only to product design but also product labelling, to ensure that warnings and use instructions are effective and do not encourage non-target uses or users.
The deadline for submitting comments to Health Canada is May 14, 2018. For more information, assistance preparing a submission to Health Canada, or assistance related to the regulation of consumer products in Canada, please contact Katherine Booth at 604-643-7198 or [email protected].