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Raising the world’s expectation of product quality, safety and supply chain responsibility

Toys and Other Children’s Products. January 22, 2010.

daniel_millan
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Raising the world’s expectation of product quality, safety and supply chain responsibility

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  1. Toys and Other Children’s Products January 22, 2010 This presentation is based on the best available information as of this webinar.  As interpretations and clarifications of the CPSIA requirements continue to evolve, the information included in this presentation may change.  STR continues to monitor the CPSIA closely and to provide recommendations and consultation to our valued clients based on the best available information. Raising the world’s expectation of product quality, safety and supply chain responsibility

  2. Consumer Product Safety Act: Notice of Commission Action on the Stay of Enforcement of Testing and Certification Requirements Interim Enforcement Policy on Component Testing and Certification of Children’s Products and Other Consumer Products to the August 14, 2009 Lead Limits Stay Informed!! Sign up for CPSIA updates at www.cpsc.gov Read STR News Alerts Specifically…

  3. Original CPSIA Schedule for Mandatory Third Party Testing & Certification for Certain Children’s Products

  4. Does not Postpone compliance with the 2/10/09 requirements Affect the applicability of lead and phthalate ban to existing inventory Stop the testing and certification requirements from going into effect but merely postpones them Postpone the testing and certification requirements which have already been implemented Does Provide opportunity for CPSC to establish rules needed for implementation of the lead provisions Provide CPSC time to rule on exemptions and exclusions from lead, and develop an approach to component parts testing Provide CPSC an opportunity to provide detailed guidance on how to comply with requirements January 30, 2009: CPSC Grants One Year Stay of Testing & Certification Requirements for Certain Products Stay scheduled to be lifted 2/10/10

  5. Stay not extended for Youth bicycle helmets Bunk beds Infant rattles Dive sticks Stay extended for all other children’s products, and GCC’s are Not Required until third party testing becomes mandatory December 18, 2009:CPSC Extends the Stay of Enforcement on Testing & Certification Requirements for Many Children’s Products

  6. Mandatory Third Party Testing & Certification of Children’s Products Currently Required Lead in Paint Cribs Pacifiers Small Parts Lead in Children’s Metal Jewelry

  7. Mandatory Third Party Testing & Certification of Children’s Products Required once Stay of Certification and Testing is lifted (for products manufactured after 2/10/10) Youth Bicycle Helmets Bunk Beds Rattles Dive Sticks

  8. Mandatory Third Party Testing & Certification of Children’s Products Stay of Certification and Testing extended Youth Bicycles (until 5/17/10) Lead Content (until 2/10/11)

  9. Mandatory Third Party Testing & Certification of Children’s Products Required 90 days after CPSC publishes laboratory accreditation requirements Youth All Terrain Vehicles Baby Walkers and Bouncers Caps and Toy Guns Youth Carpets and Rugs Clacker Balls Children’s Sleepwear, and…

  10. Mandatory Third Party Testing & Certification of Children’s Products Durable Nursery Products Electrically Operated Toys Youth Mattresses Phthalates Small Balls and Marbles Youth Swimming Pool Slides Toys (ASTM F963) Flammability of Vinyl Plastic Film (Youth Apparel) Flammability of Youth Wearing Apparel

  11. Mandatory GCC’s for Non-Children’s Products Required once Stay of Certification and Testing is lifted (for products manufactured after 2/10/10): Architectural glazing materials, ATVs, Adult bunk beds, Candles with metal wicks, CB antennas, Contact adhesives, Cigarette lighters, Multi-purposes lighters, Matchbooks, Garage door openers, Portable gas containers, Lawn mowers, Mattresses, Unstable refuse bins, Refrigerator door latches, Swimming pool slides, Products subject to Poison Prevention Packaging Act, Paint and household furniture subject to lead paint regulation (16 CFR 1303)

  12. Mandatory GCC’s for Non-Children’s Products Stay of Enforcement extended for: Adult bicycles Carpets and rugs Flammability of vinyl plastic film (adult apparel) Flammability of adult wearing apparel GCC’s not yet required for above GCC’s currently required for pool drain covers GCC’s based on “reasonable test program”

  13. Interim Enforcement Policy on Component Testing and Certification of Children’s Products and Other Consumer Products to the August 14, 2009 Lead LimitsDecember 18, 2009 Press ReleaseDecember 28, 2009 Federal Register

  14. Applies to Lead in Paint and Lead Content (lead in substrates) Allows manufacturers and importers to certify products to the lead requirements in one of 2 ways: Have test reports from CPSC-recognized 3rd party lab showing that each paint on the product complies, or Have certificates from paint suppliers declaring that all their paint on the product complies based on testing by CPSC-recognized 3rd party lab Remember that Lead Content does not yet require 3rd party testing Component Testing

  15. Paint certificate should list each paint used, by color, location or other means For each paint, certificate should identify the corresponding test report Certifying person should be able to trace each batch of paint to the paint manufacturer Product manufacturer should ensure that paints are not contaminated with lead during application to the product Wet paint tested should be “representative” of paint used on final product If drying agent is mixed with paint on final product, wet paint test sample should include the drying agent Wet Paint Testing

  16. Component certificate should identify each component tested by part number or other specification, as well as component manufacturer or supplier Plastic resins can be tested in raw state Manufacturer must take care that manufacturing process does not add lead Composite testing for lead content is acceptable! Combine like materials (plastics, metals) Raw Material Substrate Testing

  17. Reliance on certificates or raw material test reports must be reasonable Cannot be relied upon to certify product if one believes results are false or misleading Manufacturer or importer who certifies product compliance based on certificates or raw material test reports will not be subject to civil or criminal penalties if violation is found Issuer of the false or misleading certificates is subject to penalties Enforcement Policy

  18. STR does not recommend wet paint or raw material testing alone to certify product compliance Lead contamination can occur during manufacturing: Cleaning solvents used on spray masks or screens (some use leaded gasoline) Spray mask or spray gun containing residue from previous (leaded) paint, or molding machines containing residue from previous material with lead Rust (on mixing tools, stirrers, brushes, paint cans or other paint storage containers) Leaded solder used on paint storage containers or plastic grinding machines Additives to paint such as thinners, or mold release agents used in plastic molding STR will test wet paint or raw materials upon client request and based on CPSC’s Interim Policy – after discussion with client on potential issues STR Recommedation on CPSC’s Interim Policy

  19. STR overall supports component testing Eliminate redundant testing Reduce required number of samples Component testing is suitable only for certain tests Chemical, not P&M or Flame STR Recommendation on Other Component Testing

  20. Lead in paint can be done on samples that are fully painted with production paint (doll head painted with eye paint) Must use same application process and equipment as final product Finished components can be submitted Doll eyes only, not entire doll – for lead in paint, lead content, phthalates If identical components are used in more than one style, testing can be done once and results transferred Must be from same lot, produced at same factory and within same time period All styles must be identified at time of submittal In all cases, traceability must be evident Acceptable Component Testing

  21. Two day public workshop on 1/11 and 1/12 on Public Consumer Product Safety Incident Database Registration card requirement for durable infant products 6 products added to list in CPSIA: children’s folding chairs, changing tables, infant bouncers, infant bathtubs, portable toddler bed rails, infant slings Appointment of Chronic Health Advisory Panel to evaluate phthalates and phthalate alternatives Second set of 3 phthalates under interim ban (DINP, DIDP, DnOP) CHAP results in 18 months Exemption from Lead Limits for Certain Electronic Devices (16 CFR 1500.88) If not technologically feasible to eliminate lead If lead is required for function Other New CPSIA Notices

  22. CPSC website (www.cpsc.gov) Sign up for CPSC email alerts on CPSIA STR website - CPSIA FAQ (www.STRQuality.com)  STR Monitor Newsletter and News Alerts Keeping Informed

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