Protecting childhood with safer play products

For nearly 15 years, I worked as a children's product subject matter expert in human factors at the US Consumer Product Safety Commission (CPSC), after earning a PhD in human development specializing in children's play behavior. I have conducted and assisted with multiple research studies focused on child development and play. I managed a multi-year observational study by NIH for the CPSC on the age appropriateness of children's toys, culminating in the publication of the 2020 Age Determination Guidelines for the toy industry.

I learned human factors hands-on at the CPSC by conducting product safety assessments for Compliance on a range of children's products, as well as some household products intended for a general audience. These assessments frequently involved reviewing incident data reported to the Commission to determine likelihood of consumer use scenarios resulting in injury and death, reviewing instructions and warnings, examining physical samples and conducting case file reviews, and applying anthropometric data.

At the CPSC, I served as a Commission expert on age grading, toys, and playgrounds. I co-managed the age grading program for CPSC, conducting and reviewing hundreds of age grades for Compliance each year. I made improvements to the age grading database, and added tools to track and summarize timely completion. I was responsible for defending the government's position to firms contesting regulatory violations, including Commission litigation cases. I developed and led trainings on age grading across CPSC for Imports, Compliance, and General Counsel. I regularly assisted the Small Business Ombudsman in responding to questions from firms.

While at the CPSC, I led bi-weekly reviews of playground and toy incidents of injury and death to determine risk of harm and whether additional action was warranted. I was a key member of the team that produced the 2025 Public Playground Safety Handbook and would regularly answer questions from consumers about content in the Handbook. I briefed the Commission on multiple occasions, and I gave presentations at workshops and conferences on a variety of topics pertaining to age grading and children’s product safety. Additionally, I represented CPSC at ASTM voluntary standards meetings for playground equipment and wearable infant sleep products; I was actively involved in developing a new standard from the ground up, updating and renewing a standard, and strengthening safety requirements for multiple existing standards.

Since departing CPSC in late 2025, I have remained active with ASTM standards development activities for toys, playgrounds, and children's products. I am currently helping ASTM F15.09 home playgrounds develop a new voluntary standard for indoor climbing products for toddlers. I am an NRPA Certified Playground Safety Inspector (CPSI). I remain a member of the International Consumer Product Health and Safety Organization (ICPHSO) and the Society for Product Safety Professionals (SPSP). 

You can find more on my background here:

www.linkedin.com/in/khalisa-phillips

I offer age grading (or age determinations) of toys, playgrounds, and children’s products to ensure age labels are accurate for consumer decision-making, and to guide testing decisions for safety hazards that are often age-dependent (choking hazards, strangulation cord length, etc.). I am knowledgeable of the many safety requirements for toys found in ASTM F963, ISO 8124-8, and EN71.  I offer age grading for a wide range of consumer products including, but not limited to toys, sports equipment, party favors and decorations, costumes, collectibles, art supplies, backpacks, jewelry and decor. Additionally, I highly recommend age grading if you suspect your general use product may be purchased for or given to a child for play. 

I offer age grades of prototypes during the design phase to help identify appropriate laboratory testing requirements, and to support risk assessments. Additionally, I offer age grading for existing products to support contested responses to regulatory violations issued by the CPSC. As a co-editor of the 2020 Age Determination Guidelines issued by CPSC staff, I am uniquely qualified to provide age grading expertise. By remaining an independent consultant, I am in an excellent position to provide third-party assessments of products when you need a second opinion.

My age grade reports consist of a thorough analysis and description of your product’s features and functions, a recommended age, and a written rationale for my recommendation. I am well versed at issuing and defending product category determinations for products (For example, determining whether a toy is a children's product versus general use.). 

 My age grade reports fully satisfy the statutory requirements for age grading as specified in 16 CFR 1200.2 (2008). The statutory factors for children’s products also apply to toys subject to small parts requirements in 16 CFR 1501 and in ASTM F963 since they are designed and intended primarily for children 12 years of age or younger. 

Each age grade addresses the following required statutory factors:

(i) A statement by a manufacturer about the intended use of such product, including a label on such product if such statement is reasonable.

(ii) Whether the product is represented in its packaging, display, promotion, or advertising as appropriate for use by children 12 years of age or younger.

(iii) Whether the product is commonly recognized by consumers as being intended for use by a child 12 years of age or younger.

(iv) The Age Determination Guidelines issued by the Commission staff in September 2002 and any successor to such guidelines.

I offer children's product and human factors expertise to help you develop safer playgrounds and to address safety concerns. I can evaluate your playground equipment and accessories to determine intended age group(s) and foreseeable behavior and potential scenarios of misuse, provide input for risk assessments of prototypes, document non-compliant safety hazards, and support litigation for existing products subject to CPSC regulatory violations or defect investigations. 

I am very familiar with applicable standards for playground equipment such as ASTM F1487, F2373, F1148, and EN71. Additionally, my CPSI certification allows me to conduct evaluations of playground equipment, and help you determine how the 2025 CPSC Public Playground Safety Handbook guidelines apply to your play products. 

I can evaluate all active play products for your company including, but not limited to, playground equipment and surfacing, fully enclosed play structures, constant air inflatables, water slides, and trampolines. 

My company offers risk assessments of consumer products intended for infants and children. Analyses take into account factors like product size, features and functionality, child anthropometrics, strength data, foreseeable behaviors, and potential misuse scenarios. I am experienced at analyzing juvenile products for potential safety hazards (high chairs, kitchen learning towers, infant swings, etc.), and products designed for infant sleep such as swaddles, sheets, bassinets, and cribs. I can design and provide reviews of instructions and warnings, and I am familiar with many applicable standards for ASTM F15 juvenile products.