Canada and USA Publish New Guidance on Human Factors, Product Design and Risk Mitigation
Health Canada and the US CPSC have co-published joint guidance to help consumer product manufacturers integrate human factor principles into product development.
SAFEGUARDS | Consumer ProductsNO. 074/20
Health Canada and the US Consumer Product Safety Commission (CPSC) have co-published a joint guidance document to help consumer product manufacturers integrate human factor principles into their product development process. The comprehensive guidance provides industry suggestions on how the application of human factors can help lower the number of product-related adverse incidents, for example, product-related injuries, and help to mitigate potential enforcement actions and lawsuits that are often costly and impact brand value.
Human factors, as used in the guidance document, means the study of how consumers use products. CPSC staff and Health Canada developed this guidance based on a belief that oftentimes those implementing product development systems forget that the different experiences and abilities of the individual consumer, combined with varying conditions surrounding product use, could create unnecessary risk if not properly considered. According to the guidance document, the main benefit of considering human factors during product development are 1) improved usability and acceptance, 2) increased safety, 3) reduced life cycle costs and risks, and 4) reduced support costs.
Human factors can be considered in six different stages of the product design process. The guidance document outlines the following six stages, specifically:
- Product planning
- Idea and concept generation
- Design and development
- Testing and validation
- Post-production evaluation
CPSC and Health Canada suggest the product planning stage is important since identifying the target market, how the company plans to handle consumer complaints, and other aspects of the planning process will make it easier down the road for a product designer to correct any potential problems with well-reasoned contingency plans.
The guidance document’s suggestions for the last four stages primarily concern risk reduction. During the design and development stage the guidance document suggests designers look at human factors of the target consumer to evaluate possible misuses of the product and develop processes to decrease hazards among that population. The testing and validation stage, which the authors indicate should be repeated throughout the product design process, should include human factors components to make sure tests evaluate the product as it will be used by consumers, and not just in lab conditions ill-suited for evaluating the product as it will be used. This includes considering both the skill of the expected consumer as well as the environment and conditions where the product is likely to be used. During the production stage, the guidance document suggests manufacturers consider human factors to ensure safety and decrease hazards both with the product use and for workers during the assembly process.
CPSC and Health Canada believe implementing human factors into the design and production of a consumer product could lead to safer use and prevent recalls down the line that would harm a company’s market share.
It is worth noting that the guidance document is not an official rule or regulation and does not create any legal obligations or independent causes of action in any jurisdiction.
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