In this episode of WTFFF?!, 3D Printing Safety First, we have an interview from down under with Gail Greatorex from Product Safety Solutions. We talked with her via social media a long time ago, when we first started the podcast. She was pointing us to material safety data because we were talking about filament, air quality, and some of those things at that time. She was also pointing out other significant safety and quality issues, so we have been wanting to have her on the podcast for a while. I’m glad we finally made that happen with the time difference.
3D Printing: Safety First
Recently we had the opportunity to talk with Gail Greatorex of Product Safety Solutions in Australia. We had communicated with her via social media a long time ago. It was a situation where she was pointing us to material safety data because we were talking about filament, and air quality at that time. She was also pointing out other significant safety and quality issues regarding 3D printing: safety first, so we finally arranged to interview her and have a more in-depth discussion about some serious concerns of 3D printed product safety.
Slide share: 3D printing product safety http://www.slideshare.net/search/slideshow?searchfrom=header&q=3d+printing+product+safety
ScoopIt curation page: 3D printing & product safety http://www.scoop.it/t/3d-printing-and-consumer-product-safety
Questions for Gail:
How did you get into Product Safety and 3D Printing?
I have been in product safety for 25 years with the Australian Competition and Consumer Commission, the equivalent of the CPSC in the USA. I left the ACCC in 2012 and set up my own product safety consultancy, then about a year ago I became intrigued with 3D Printing, especially the more affordable desktop 3D printers. So I decided to get the conversation started and published a white paper in January of 2015.
It is not just about material safety of filaments, is it?
In product safety there is a hierarchy of how to insure the safety of products, and it starts with design. You can have the greatest impact of the safety of your product at the design stage, after that it is looking at protective devices that can control the hazard, then the lowest on the hierarchy is providing warnings on the product. You do not want to rely on warnings when you can design the hazard out of the product. Safety of a product should be designed in. In the USA, more retail products are designed by people in foreign factories who do not understand the US market, or the US Consumer Product Safety regulations.
You have a slide share where you point out some scenarios where unintended consequences can cause product safety concerns, can you share some of that with our audience?
I call it the democratization of manufacture, the same way that web sites like eBay brought about the democratization of retail so anyone can sell anything at any time. Now with 3D printers anybody can design a product and anybody can print and make their own product, but it is not the same as in manufacturing where there is a system of employees, designers who are professionals and have qualifications of design, quality control systems, consistent manufacturing with process controls, among many other systems that contribute to making a safe consumer product. All of those systems are not in place in consumer level desktop 3D printing. There is nothing to stop any individual from creating or downloading a 3D printed product they want to and selling it on Etsy or eBay with no product safety considerations whatsoever. Major retail chains each have their own quality standards and procedures, but products sold outside of that system do not. While 3D printed products are made in small numbers today, it does not take large numbers to create a product safety problem.
How does the inconsistency of the output of 3D printers factor into this?
Even if a professional designer creates designs that are well thought through, once they offer them up for download for others to print on their own 3D printers, it is very easy to alter the 3D printed result from the intended quality. There are so many variables in printing the design including material, infill percentage, layer thickness, temperature, wall thickness, and many others, that a printing technician can easily transform a well designed product into an unsafe one. The print setting decisions made by the technician printing the products are so critical to product safety.
There are many inherent complexities in this issue. We have considered the variables with regard to safety and product quality and found that it would be better if we offered gCode files for download rather than 3D model files, so that we control the settings, the variables, to maintain quality. The problem is that there are so many different printers that it is very costly and time consuming, perhaps not even possible to make gCode files available that will work on all 3D printers. What do you think about that Gail?
Indeed, and so Designers, at least, need to think about the instructions for people doing the printing, and also the warnings and instructions for the ultimate consumers. So there are two levels of instruction that designers need to think about when turning their minds to safety.
What happens when the prosumer customer prints on one 3D printer in their home, then they buy more, and they build up to having several. What kinds of air quality problems might they have in their home?
Well, this is a bit outside my area of expertise, but I do have some links to some related articles. Of course there are some airborne particles that are of concern.
What about banned products? Is that a significant concern?
Well indeed, products do get banned from time to time, when there is no alternative to make it safe. Especially if there have been injuries associated with the product, it can be banned.
Is the Desktop 3D Printing Industry too small an industry to regulate?
One of the interesting and complex issues with product safety in this area is that someone can scan a banned product and replicate it, then print it out on a 3D printer. So it is another consideration if you can make more of a banned product so easily.
I think new laws need to be written on design and design files due to the disruptive nature of 3D printing. I wrote about this in my white paper. I really did my white paper to get the conversation started, but everyone needs to play a part in the safety of products.
What tips do you have for prosumer listeners of ours, or areas they should research before selling any of their 3D printed products?
- The very least you can do is go to the consumer product regulator and see if there are any bans on a product. You can also check the product recalls, because that is really some useful intelligence you can use to see if your product may be at risk. recalls.gov.au
- You can type the name of the kind of product into Google and then the word “safety” to learn about concerns on products before you create a particular product. There might even be advice on how to make the product.
- Designers need to get to get a handle on the possible hazards for their products, and provide warnings and instructions for their designs to the people who may print them, and to the end consumers who may use them.
- Prosumers must follow the instructions provided for the designs they produce, choose good quality materials to print them in, and make sure their printers are maintained in good working order.
That was a much more interesting interview than expected. You never know what it’s going to be until it happens, no matter how much background research we do, but to us, this brought up a lot of issues that no one is really considering in this industry.
When you are getting free files or are just deciding to go out on your own and start making these things, even we don’t know all the problems that are going to happen with our designs yet because this is a new process with new materials.
This is almost a sleeper issue in this industry, which is going to become a bigger problem. Think about it: the brick-and-mortar retailers that people traditionally sell products to—I don’t even think Amazon does anything like this—if there is going to be a product on the shelves in their stores, they have testing requirements. Walmart has their own, Target has their own, Costco has their own, and you can go on down the list.
A lot of these design libraries—or if you want to call them design repositories, ones that have designers featured—don’t have these considerations; they talk about how they may curate the designs so they are all printable, but are they safe? I don’t think anyone is really looking at that and policing that.
If you think about it, how can they? When you think about brick-and-mortar retail, you distribute a product into that pipeline, and you will be selling them 5,000-6,000 units at minimum, and sometimes up to 25,000-30,000 units. When the volume is that large, the retailer can demand the vendor go and pay for an independent testing lab to test their product, and they test it not just to see if it performs how it’s intended, but they put it through stresses that simulate ten years of use. It would be impossible to conduct that kind of testing for every individual 3D printable download.
Gail was saying it’s considering consumer behavior in unintended ways. I always believe that the misuse of the product is a greater sign of bad design because if you misuse it, that’s because it wasn’t logical to use it properly, or it wasn’t intuitive and properly designed for a user’s process. You’ve done something wrong on the design side unintentionally.
Think about the complexities of individuals all over this country and all over the world—and even small businesses as we are promoting and hoping they will start their own small businesses using 3D printing. Is this a huge, litigious nightmare? I worry that it is. I don’t want to scare our audience, because I still believe 100% in the 3D printing industry, and there has to be a way to handle it. But so far, I don’t see a way to handle it.
What I think is really good about this interview with Gail is she brought some really good, serious issues to the front of our consciousness. I think as designers, as anybody who is going to manufacture a 3D printed item on their own and sell it, or as anybody who is going to distribute any 3D-printed article, it is critical to do some amount of due diligence. Considering the products that they are sending out, any kind of warnings, recommended requirements, or limitations for how it’s used all have to be communicated to that consumer. As someone who is shipping a product, whether you’re Shapeways, Materialize, or an individual on Etsy or Amazon, you really should pay attention to this and be doing the best that you can to make sure that people know how the product should be used.
We have extremely high design quality standards. Because we uphold them for all of our other clients, we expect to uphold them even higher for ourselves. Even sending a design file across the Internet to someone’s local printer, we expect to uphold our same quality/safety standpoint, so it’s our integrity that is at stake here. It’s really hampered our ability to go out there and do products for 3D printing. Even if we were looser about those standards and just got our stuff out there because our designs are very good, it’s still a big unknown.
I wonder if there is an opportunity here for the brick-and-mortar retailers to make themselves more relevant online with products that they might sell that are printed on demand: if they can come up with a way to resolve this problem of controlling the quality and insuring the minimum safety requirements are being met. They would really have to provide a way of doing that or work with big enough outfits who are going to do that for them. I think that’s really the thing.
You can’t just open it up like on Etsy where you are opening it up to just anyone without any qualifications. In this case, you have to work with professional manufacturing facilities who know what they are doing and are going to make it day after day with the same quality standards where the printers are maintained, which can be a big issue. If you are going to print the product and ship on demand, you will have to do it that way. Retailers need to start to consider this.
At a certain level of business, the liability is so low. It may not be as big of an issue. But certainly as the industry grows, as it goes more to regular consumers getting involved that are not professional designers and engineers in 3D printing, it becomes a bigger issue. We will have to keep our eyes on it.
Again, not to scare everybody away from 3D printing because that is certainly not the intent here. I think we all need to be very well aware of these issues, those of us involved in making the products. Especially be concerned about anything you make for small children.
I think that regardless of what you are making, a good best practice would be—whether you are selling it on Shapeways, Pinshape, Materialize, or any other method—have a key list of criteria for acceptable, intended use and maybe even the age range of use. These are things that companies do for products you buy at retailers all of the time. Serious recommendations about how to print it, too. How thick should the walls be, what materials… If you don’t know what it should be, ask someone who might know and get some recommendations.
Gail Greatorex is a product safety consultant and advocate, and Director of Product Safety Solutions in Australia
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