Create a Risk Analysis for PDF Documents
What dangers could possibly be hidden in a knitting pattern? The GPSR regulations require us to carry out a risk analysis for our PDF documents. But what does this mean if you write knitting, crochet, sewing, quilting, or other craft patterns?
8 minute read.
In this blog, I will examine what the regulations say we need to do, why we need to do it, and how we can meet these requirements in simple, quick, and stress-free ways, so we can keep doing what we love.
Why Do We Have Safety Regulations?
Sometimes, products can cause harm, or even be fatal. I recently read a tragic story about a child who swallowed a battery from her toy. The toy dispensed sweets, the battery fell out, and it was the same size as a sweet. Thanks to her mother’s quick response, she survived, but she suffered life-changing injuries as the battery burned through her stomach.
Over time, every country has developed safety regulations for products that are bought and sold. These rules are usually based on evidence, evolving as new risks emerge.
A simple example of Safety Regulations that protects our eyesight.
Take sunglasses as an example. Initially, they were designed to protect eyes from UV rays. But as they became a fashion accessory, some brands started selling ‘fashion’ sunglasses without UV protection. These could cause serious eyesight problems if worn outdoors in bright sunlight. They trick the eye into not reacting to bright light, while providing no real protection. In response, safety regulations were introduced worldwide. Today, it’s illegal to sell sunglasses in the EU without clear labelling of their UV protection level.
In the US, sunglasses are regulated by the FDA. Canada has its own voluntary guidelines, as does Australia. Each region legislates in its own way. Some regions (Australia and the EU) allow the sale of ‘fashion’ sunglasses or toy sunglasses, as long as they are clearly labelled with warnings. Other regions do not allow the sale of anything that could be mistaken for sunglasses, unless they have UV protection. Canada’s standards are voluntary, while other regions are compulsory. But most parts of the world have some standards that apply.
How Online Sales Changed Safety Regulations
The rise of online shopping disrupted national safety laws. Traditionally, if a pharmacy imported sunglasses, they had to comply with local regulations. But when people started buying directly from overseas retailers on platforms like Amazon, eBay, Temu, and Shein, there were no requirements. Unsafe products were reaching consumers unchecked. Today, I quickly looked at sunglasses for sale on the four platforms listed above, as well as Boots Ireland, and Brown Thomas (a large Irish department store.) Of the six, only Boots were fully compliant with the regulations, and had the UV protection level of the sunglasses properly labelled.
To fix this, the EU now requires that all products sold online into the EU must prove compliance with EU safety laws.
Unfortunately, digital craft patterns got caught in the crossfire. Unlike a faulty toy with a battery, a crochet pattern PDF can’t cause harm. And unlike unsafe sunglasses, it won’t make anyone go blind. Instead, our patterns are among the lowest-risk products imaginable. But because the EU made no exceptions, we are included in these new regulations.
While safety laws exist for good reasons, it’s also important to keep perspective: our digital patterns are extremely low risk.
What Dangers Could a Pattern Possibly Pose?
We can assess risk in two ways:
1. The safety of the PDF document itself.
2. The safety of the finished item created from the instructions.
In this blog post, only the first issue is being addressed – the safety of the PDF document itself. It is the PDF download we sell, and therefore, it is the safety of that document we must stand over. There are separate issues of responsibility for the finished item. Our pattern may suggest a technique to knit, crochet, quilt or otherwise make a baby blanket. And that baby blanket, when finished, might not meet basic standards. However, this is a secondary risk, as the baby blanket isn’t actually the product we sell. Next week’s blog post will focus on the complex issue of safety of finished items.
By my estimation, a PDF pattern has four possible risks. These are all minor and unlikely, but worth considering before launching a pattern.
Risk 1: A PDF with a Virus.
Risk 2: Unsafe hyperlinks.
Risk 3: Poorly formatted layout.
Risk 4: Inappropriate content.
Protecting PDFs from viruses
This is the kind of risk that the EU is trying to prevent. However, a virus cannot get into a PDF unless someone deliberately adds it. So don’t lose sleep over this!
Virus safety for PDFs
Use strong passwords on the device you use for pattern writing.
Keep your antivirus software reasonably up to date.
Trustworthy hyperlinks
Most patterns contain hyperlinks, whether to our own websites and social media or to external tutorials. When conducting a risk analysis for PDF documents, they are something we should consider.
The problem? Links can become unsafe if they are hacked or redirected. For example, if your Instagram account is hacked, a ‘Follow me on Instagram’ link in an old pattern could take users to a phishing site instead.
Safe links for PDFs:
Prioritise links to your own website or newsletter over social media. You own your mailing list, Meta owns your Facebook and instagram feeds. It’s best to direct feeds where you have most control, and lowest risk of future loss.
Only use trusted sources for tutorials. Focus on established educators rather than random YouTube links. If you are sending links to other people, make sure you know and trust them.
Regularly check your links to ensure they haven’t changed.
Poorly formatted PDFs
Bad formatting won’t cause permanent harm, but it can cause eye strain, headaches and other problems. And those minor problems can spiral. Just ask Ravelry. Poorly chosen colours, fonts, or layouts can make patterns difficult to read, leading to frustration for users, and ultimately coming back as negative reviews for the designers.
Best practice for pattern layouts:
Use at least 12pt font
Ensure clear contrast between text and background.
Consider developing your own style sheet or best practice approach. Good resources can be found from the Center for Excellence in Universal Design, for from the British Dyslexia Association Dyslexia Friendly Style Guide. (This is the one I use personally, possibly because I am dyslexic myself, I find it easier to apply, with clear results).
Inappropriate or Offensive Content
Can a craft pattern be offensive? Possibly. Again, we can ask Ravelry. The GPSR law uses the WHO definition of health, which includes mental well-being. By this definition, if a pattern could cause someone great distress, it is defined as creating harm, and therefore not being a safe product.
In an increasingly divided world, different cultures and groups have different established concepts of what is appropriate. Growing up, I was always told that it was not ‘polite’ to discuss 3 things in public. Ever. Those three things being sex, politics and religion.
My personal stance as an adult is in a firm commitment to free speech. If a designer wants to create a graphgan chart depicting a scene of lovemaking, a dedication to their faith or to their political affiliation, I will stand by their right to do so, even if their position is the opposite to my own.
However, I will also stand by the right of the person who doesn’t want to unexpectedly find themselves encountering this content without consenting to it.
Furthermore, some imagery is explicitly illegal in certain EU countries (e.g., swastikas in Germany, extreme pornography in many EU nations).
Best Practice for sensitive content
If a pattern contains mature or controversial themes, clearly state this upfront so buyers can make an informed choice. Identify the risk, and make an appropriate statement in the listing.
How to Conduct a Risk Analysis for PDF Documents
To be GPSR-compliant, designers need technical documentation assessing their pattern’s safety. This sounds complicated, but in reality, it’s just answering a few simple questions:
1. Is the PDF virus-free?
2. Are the hyperlinks trusted and checked?
3. Has the pattern undergone quality control (testing, tech editing, or peer review)?
4. Is the layout clear and accessible (at least 12pt font)?
5. If it contains sensitive content, is this clearly stated?
To comply with having ‘technical documentation’ a designer needs some record that they have carried out a risk analysis for PDF documents. It could be a form they fill in for each pattern. out it could be an excel spread sheet they keep, and add a new Column for each pattern. However it is done, it shouldn’t be a difficult process, but rather a momentary action of ticking a box.
By taking these small steps, we can comply with regulations without stress and keep focusing on our love for craft!
To hear more about how GPSR impacts designers and yarn crafters, sign up here!
