Consultation for the review of the mandatory standard for hot water bottles

We believe ACCC Regulations should be identical to BS1970:2012, including all test methods. All manufacturers primarily produce for the larger UK/Europe markets (which adopt BS1970:2012), and hence consistency in Australia is important.

We believe ACCC Regulations should be identical to BS1970:2012, including all test methods. All manufacturers primarily produce for the larger UK/Europe markets (which adopt BS1970:2012), and hence consistency in Australia is important.

It should provide the exact wording requirements which all suppliers must comply with, but allow suppliers flexibility in formatting requirements.
(eg some products are in polybags allowing one format, other products have swing tags which require another format).

We do not feel it is necessary to stipulate adding cold water first.

Our actual wording recommendation is as follows:

"When filling this hot water bottle, do not use boiling water and fill to a maximum of two thirds capacity or less. Do not overfill as this might cause the bottle to burst. Hint: pour cold water into an equal volume of boiled water in a kettle or jug"

For our full suggested text, see point 12.

We believe it is important to co-ordinate the ACCC required warnings with the mandatory warnings/instructions in BS1970:2012 (clause 8 - except the reference to European manufacturer or UK distributor in clause 8.1)

We largely agree with the proposed warnings and instructions from Appendix B, but with some slight variation.

The text we believe to be most appropriate for consumers is as follows (easy to read, covers intent of Appendix B and also complies with BS1970:2012):

This hot water bottle is made from Natural Rubber.

GENERAL Warnings

• WARNING - HOT WATER BOTTLES CAN CAUSE BURNS.
• AVOID PROLONGED DIRECT CONTACT WITH THE SKIN.
• NEVER fill with boiling water, it can cause damage and bottles may burst.
• NOT recommended for children or anyone with reduced feeling or delicate skin
• REPLACE at least every 3 years.
• REPLACE earlier if damaged or worn, e.g. cracked, splitting, colour has changed, feels brittle, stopper leaks.
• Do not fill using water from the domestic hot water system as this can considerably shorten the life of the hot water bottle.

IMPORTANT Filling Instructions

1. When filling this hot water bottle, do not use boiling water and fill to a maximum of two thirds capacity or less. Do not overfill as this might cause the bottle to burst. Hint: pour cold water into an equal volume of boiled water in a kettle or jug
2. Hold the bottle by the neck in an upright position and fill slowly to avoid hot water splashing back onto your hands or body. Hint: hold bottle over sink and away from your body while filling.
3. Expel air from the bottle by lowering it carefully onto a flat surface until water appears at the opening.
4. Screw the stopper sufficiently tight to ensure that there is no leakage. Finger-tight should be adequate.
5. Finally, make sure the funnel is empty. Hold the bottle upside down over sink, away from body. Squeeze LIGHTLY to check for leaks.

IMPORTANT Usage Instructions

• If there is a possibility that prolonged contact with the skin could occur, an adequate cover should be used to prevent burns. Wrap in a towel or a covering - do not place bottle in direct contact with skin.
• Under no circumstance should the hot water bottle be used as a cushion and be sat on. Also, do not lean on, rest your legs on, or put pressure or weight on bottle.
• Do not sleep with bottle overnight. Remove before getting into bed.
• Never heat bottle in oven or microwave oven.
• Prevent contact with hot surfaces.
• Prevent contact with oil or grease.

IMPORTANT Storage Instructions

• When not in use, drain completely and keep, with stopper removed, in a cool dry, dark place. Hint: Hang upside down to dry before storing, and allow to fully dry before storing.
• Do not place anything on top of the bottle during storage.
• Prevent exposure to sunlight, moisture, oil, grease and heat.
• Check the bottle and stopper for wear and damage prior to use.

Retain these instructions for future reference.

PLASTIC BAGS CAN BE DANGEROUS. TO AVOID DANGER OF SUFFOCATION, KEEP THIS BAG AWAY FROM BABIES AND CHILDREN.

The tag/disc size, design and material should be up to the supplier. It could be attached to either the bottle or the cap. We suggest the only mandatory text on the tag/disc should be as follows:

"DO NOT USE BOILING WATER.
CHECK FOR WEAR AND DAMAGE PRIOR TO USE"

The use of embossed contrasting colours is not technically possible on moulded rubber products such as hot water bottles. If this becomes a requirement, no manufacturers will be able to supply into Australia.

The supplier must be able to have the option of using alpha or numeric dates on the packaging. For example 01.2014 or Jan 2014. The reason is that application equipment with manufacturers varies.

We believe that the point of sale information on the packaging is sufficient as per our suggested wording detailed in point 12. Display material at point of sale is not always possible at store level, and would be impossible for suppliers to guarantee and maintain.

A lead-in period of 24 months should be allowed before the new requirements commence. This allows the supply chain to sell through stock, in particular that stock which is carried across from one season to the next.

1. We suggest the ACCC should mirror the BS1970:2012 in all regards except the clause 8.1 reference to European manufacturer or UK distributor.
All manufacturers are focussed on the much larger UK/EU markets, and gear their factories to these requirements. If Australia deviates from this, it may limit the capability of quality supply into Australia.

2. Points 25 and 26 of Appendix A directly contradict BS1970:2012. Given that all manufacturers emboss hot water bottles with BS1970:2012, the adoption of 25 and 26 would make supply to Australia impossible. Further to this, we are of the view that hot tap water should not be used (as specified in the mandatory instructions of BS1970:2012).