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To view our previous webinar “Compliance Strategies, Testing Solutions for All”, please click this link.

If you have trouble viewing the above presentation, please view these documents:

The Regulations
The Instrumentation
The Analysis

To View a presentation on CPSIA Testing for Youth Furniture, click here
(requires Windows Media Player)

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Consumer Product Safety Commission

Protecting Consumers and Families

Lead in Children's Toys, Jewelry, and Paint

Testing for Lead Content in Children's toys

Phthalates in Children’s Toys  and Child Care Items

Testing for Phthalates in Children's Toys

Questions & Answers from the webinar, “Compliance Strategies, Testing Solutions for All"

Are the TPCH packaging requirements for both adult and children’s packaging?
Yes, the TPCH requirements are for products that are intended for both adults and children.  The main purpose of the toxic packaging regulation is to limit toxic elements entering the waste stream.

Does TPCH only apply to the packaging itself (polybags, cartons, hangtags, etc.) and not apply to the handbag or cosmetics case (which is what we manufacture)?
TPCH applies to the product packaging and not the product itself.  It is the plastic, cardboard, etc, in which you package your cosmetics cases for retail that are subject to TPCH.

I own a children’s consignment shop in Alabama.  One of my many questions is how can we affordably test?   Most of the items we sell are between $3 and $6.  A $25K-$40K XRF gun is NOT cost effective.
You have several options. You can consider hiring someone to sort and screen items in your store using XRF technology (several companies offer this sorting service at a reasonable price) then send the items of concern to a 3rd party CPSC certified lab like Chemserve for ICP analysis.  You can also send the items off to a lab like Chemserve, where they can sort and screen the items with XRF then submit only those items that raise a concern for ICP analysis.  Whichever way you choose, the children’s items need compliance with the lead laws if you are to sell them.

I was advised that all items under the CPSIA must be tested by a third party lab and XRF machine results are not considered valid – please comment.
Under the CPSIA, certain children’s products (products manufactured, labeled and/or intended for use by children under age 12) are required to be third party tested for lead. The role of XRF in this process is still in flux.  XRF has become a well-accepted screening technique, both to identify items of concern as a first step in laboratory testing and to ensure continuous compliance on the production floor in a straight-forward manner. The point under review is whether XRF results can actually be used in their own right in laboratory testing for certification.

The CPSIA stipulates in sec. 101 (f) (4) that the Commission shall complete a study on the effectiveness and reliability of XRF. This study was released on August 14th (http://www.cpsc.gov/ABOUT/cpsia/leadinpaintmeasure.pdf) and concludes that "XRF is suitable in many cases for the accurate determination of lead in plastics". This confirms Standard Operating Procedure CPSC-CH-E1002-08, which states that "XRF can be used with limitations to quantitatively determine the amount of lead in homogeneous polymeric materials by following ASTM F2617-08".  

A draft federal register document outlining the accreditation for laboratories following, amongst others, this standard, is currently under review (http://www.cpsc.gov/LIBRARY/FOIA/foia10/brief/totallead.pdf).  It is thus possible that XRF will in the future become a certified third party laboratory testing technique in its own right for at least some applications related to the CPSIA. For the moment, however, ICP is the method of choice while XRF has a very useful role to play in reducing the workload by enabling initial and continuous screening, both in the analytical testing lab and in manufacturing and warehouses.

I was advised that lead in coating does NOT apply to consumer products such as those listed under Chapter 42 (handbags, cosmetic cases, backpacks, etc) – please comment.   
We are not familiar with Chapter 42 of the CPSIA so cannot comment on that exemption for lead coatings.  However, if any of these products are for children 12 years and under then compliance with lead content limits must be certified by a third party, CPSC accredited lab.

I was advised that PVC handbags, cosmetics, coated zip pulls do not have to be tested under CPSIA – these also fall under Chapter 42 – please comment.
If your consumer product is for an adult, you don’t have to test for CPSIA compliance. 

Does a snap on a baby one-piece need to be tested by third party testing lab as well?
The snap on the baby one-piece would be exempt if it were made of stainless steel (unless it is identified as 303Pb because this alloy contains lead) or precious metal only.  Anything that is manufactured for children and is included in the CPSIA regulation will require third party testing unless it is exempt under the CPSIA, as cotton is.

Do I understand correctly that zippers and buttons in or on children’s clothes DO have to be tested?Yes.

Our supplier has the certificate for the snap. Can we use the certificate from our supplier?
No.  At this time you cannot use the certificate from the snap supplier as your certificate of compliance.  This is due to the way that the regulation is written.  That is that the CPSIA compliance is based on finished goods being compliant vs a product’s components being compliant.

What is the current regulation regarding crystal stones?
The regulation states that if the stone is not associated in nature with any mineral that is based on lead or lead compounds you don’t need to test (precious and certain semi-precious stones).  However, some minerals are known to contain lead or are associated with minerals that contain lead so would require testing if they are used in any children’s products.

Under the new ruling, materials exempt from the CPSIA lead laws now include cotton that we use for baby one-piece. But if we put a stamp or screen print on the shirts, do we have to test for lead in paint for the prints? Does it need to be tested by a 3rd party?
The stamps and prints that are added to the cotton one piece need to be tested for lead.  And the analysis needs to be done by a third party CPSC accredited lab.

I am manufacturing a backpack for kids 5 years and up.  Do I need to test the zippers for small parts or just lead paint?
The zippers have to be tested for lead paint and lead content.  The backpack materials also have to be 3rd party tested for lead content.

Because Chemserve is not certified to test for small parts, we cannot comment on whether the zipper is required to be tested for this.  We suggest you check with the CPSC directly on this question.

 

We manufacture diaper bags intended to be used by parents.  The only part intended to be used by children is the changing pad.  Are we subject to the Phthalates law in regards to the bag and/or changing pad?
The changing pad needs to be tested for lead.  If the pad were ever to be used for sleeping purposes, it would be subject to the phthalate regulation and need to be analyzed for phthalates.  The phthalate regulation applies to all child care products used for sleeping, feeding, teething or sucking.  We suggest you check with the CPSC directly on this question, too.