Button battery safety - Assessment of regulatory options - Consultation paper

Response 550980231

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Consultation Paper Questions 1 - 7

1. The ACCC considers the status quo and proposes three options to improve the safety of button batteries. Which is your preferred option and why do you prefer it to the others?

The ACCC considers the status quo and proposes three options to improve the safety of button batteries. Which is your preferred option and why do you prefer it to the others?
We support option 3
We have already adopted an approach to coin/button battery safety based upon the published ACCC industry code published in 2016

2. What effect do you believe each of the proposed options will have in saving lives and reducing severe injuries caused by button batteries?

What effect do you believe each of the proposed options will have in saving lives and reducing severe injuries caused by button batteries?
We believe that all the options will contribute, but probably the marking is the most important to promote awareness

3. Provide comment on the ACCC’s essential requirements for secure battery compartments, child-resistant packaging and warnings and information. Are there any additional requirements that should be included?

Provide comment on the ACCC’s essential requirements for secure battery compartments, child resistant packaging and warnings and information. Are there any additional requirements that should be included?
No further requirements

We are not particularly keen on the ACCC warning symbol, though we have been using it - we would probably prefer the AS/NZS 62115 symbol

4. In relation to the requirement for secure battery compartments in which button batteries are only accessible with the use of a tool, do you consider that the use of a ‘tool’ should include the use of a coin? Why/why not?

In relation to the requirement for secure battery compartments in which button batteries are only accessible with the use of a tool, do you consider that the use of a ‘tool’ should include the use of a coin? Why/why not?
The use of a coin as a tool has been long established in other standards, so should stay.
However some coin slot covers are too easily removed and can be operated by fingernail so there should possibly be some better definition of the torque/force required to operate such covers

5. Do you supply products that currently meet the essential requirements for secure battery compartments, child-resistant packaging and warnings and information? If not, which requirements do your products not meet and why?

Do you supply products that currently meet the essential requirements for secure battery compartments, child resistant packaging and warnings and information? If not, which requirements do your products not meet and why?
The majority of products meet the requirements. Some older products may not have warnings updated, but we did review some time back and I believe they should comply.
Occasionally some packaging of accessory batteries not fitted in product and packed in China may not have child proof packaging.

6. Provide comment on the ACCC’s proposed information standard for warnings and information to be made available at point of sale. Are there any additional requirements that should be included for products sold online, or for unpackaged products supplied to consumers?

Provide comment on the ACCC’s proposed information standard for warnings and information to be made available at point of sale. Are there any additional requirements that should be included for products sold online, or for unpackaged products supplied to consumers?
We are trying to include warnings on exterior of packaging to provide point of sale information.
We would need to consider how best to link warnings for online
Unpackaged product not really relevant to us

Consultation Paper Questions 8 - 14

8. Do you agree with the proposed exemption for hearing aid devices and associated zinc air batteries? Please explain your reasons. (See section 5.2)

Do you agree with the proposed exemption for hearing aid devices and associated zinc air batteries? Why/why not? (see Section 5.3)
Yes
I can understand that hearing aid batteries comprise lower risk, and that the main users are possibly elderly and would find difficulty and frustration with tamperproof packaging

9. Do you consider that any other categories of consumer goods should be exempt from any of the proposed requirements? Do you have information and data you can provide to the ACCC in support of your view?

Do you consider that any other categories of consumer goods should be exempt from any of the proposed requirements? Do you have information and data you can provide to the ACCC in support of your view?
No

10 . What are the likely costs to implement each of the requirements (design changes, child resistant packaging, labelling), and what do you consider is the likely effect on prices for consumers?

What are the likely costs to implement each of the requirements (design changes, child resistant packaging, labelling), and what do you consider is the likely effect on prices for consumers?
As we are already trying to comply with ACCC code, there should not be effect on price and we have tried to absorb all costs so far

11. Do you think that all potential costs to business have been considered? Can you provide any further information about the likely cost and impact of each of the options?

Do you think that all potential costs to business have been considered? Can you provide any further information about the likely cost and impact of each of the options?
N/A

12. Provide comment on the transition period for the proposed options. (See section 7)

Provide comment on the transition period for the proposed options (see Section 7).
Transition period is acceptable to us

13. Provide comment on the principles-based approach to a mandatory safety standard. (See section 7.2)

Provide comment on the principles based approach to a mandatory safety standard (see Section 7.2). A principles based approach: • Sets out safety principles that need to be met rather than specifying detailed standards • Incorporates external instruments for compliance tests only • Includes administrative guidance which provides examples of relevant clauses in external standards that are considered to comply with each requirement.
Happy with this approach

14. Provide any additional information or data that you think may be useful for informing the ACCC’s recommendation to the Minister.

Provide any additional information or data that you think may be useful for informing the ACCC’s recommendation to the Minister.
N/A