Component Testing Pitfalls

What to look for when evaluating how to test your toys

By Susan DeRagon -- Gifts and Dec, February 1, 2010

It’s been over a year since the Consumer Product Safety Improvement Act (CPSIA) went into effect and many toy manufacturers and importers are still struggling to implement a cost-effective, reasonable testing program. The Consumer Product Safety Commission (CPSC) has worked closely with the toy industry to provide additional guidance and clarification, including the recent adoption of an interim enforcement policy allowing component part testing. If done prudently, this can be a sensible and cost effective method of complying with the CPSC’s testing requirements.

CPSC’s current policy

Under the interim enforcement policy, which became effective on Dec. 16, 2009, manufacturers and importers have two options for certifying product compliance: follow CPSC’s initial requirement and have the final product tested by a certified independent third party testing laboratory; or accept certificates from component suppliers that declare that the component complies with CPSIA limits, based on appropriate testing.

Component testing reduces or eliminates redundant testing and decreases the number of final product samples required to obtain sufficient test sample size. While this would clearly reduce the cost of testing, adequate traceability of the components to the final product is critical to the success of component testing. Manufacturers and importers are ultimately responsible for product compliance, and they must ensure that testing done on components directly correlates to the final product that is placed on the market and into consumers’ hands.

Until the CPSC provides additional clarification, manufacturers and importers should look at the following issues when evaluating whether to utilize component testing to meet CPSC testing requirements:

Type of test. Component testing is suitable only for certain tests in which the final product is not required to appropriately test and determine compliance. Chemical tests such as lead in paint, lead content and phthalate content are examples of tests in which component testing would be appropriate. Physical tests, including mechanical safety (use and abuse) and flammability of toys and other articles intended for use by children, (16 CFR § 1500.50) typically require the finished product, so component testing is not suitable.
Representative samples. For any testing to be valid, a sufficient number of random samples must be tested to ensure they are representative of the final product. For example, the test for lead in paint and similar surface coatings (16 CFR § 1303) often requires the destruction of numerous samples to obtain sufficient amount of coating to test. The coating is typically removed by scraping the paint off of the substrate to which it is applied. A reasonable, efficient testing program would yield a sufficient amount of paint or coating for valid testing, while minimizing the number of samples needed.
To illustrate, consider a doll whose entire head is painted with the same paint as is used for the eyes. With component testing, it is possible to test for compliance of the paint used on the eyes of the final product by testing paint samples taken from the doll’s head. However, certain parameters must be in place to help ensure that the samples submitted for testing are “representative” of the final product. In addition to the painted heads having the identical paint used on the eyes, the painted heads must be prepared at the same factory using the same equipment and same painting technique as for the eyes. If the eyes are spray painted, the doll head should be spray painted using the same spray guns. If the painted decoration on the eyes is stamped on, then the doll head should be stamped multiple times using the same pad printer or stamp. These parameters will provide validity of the component test results to the final product.
Final component testing. An acceptable alternative to the techniques described above would be to allow for the painted components alone to be submitted for laboratory testing. Rather than submitting numerous dolls whose eyes would then be scraped, the painted eyes could be submitted prior to final assembly into the doll. If the doll head requires testing for phthalate content, the doll head alone could be submitted—without the eyes and without the body of the doll.
Eliminating redundant testing. Component testing should allow for the elimination, or at least reduction, of redundant testing. Illustrating again with the doll example, if the same doll eyes are used in several styles of dolls, testing of these eyes may be performed once and the test results used to certify compliance of all styles that use the identical eyes, provided all styles use the eye components from the same lot or batch and traceability is evident. As another example, if the identical plastic is used to mold various dolls’ arms, legs and torso with the only difference being the configuration of the molds themselves, testing of a molded plastic component once for lead content (and phthalates if applicable) may be permitted, provided the molded components use the same lot of material and are produced at the same factory during the same time frame. Again, as with any component testing, traceability is critical.
Raw materials testing. Testing of raw materials alone to certify compliance of the final product raises the concern of possible cross-contamination during production. While this problem is usually not seen in factories using good manufacturing practices, there is always a potential for contamination of raw materials, including wet paint/coatings and plastic pellets.
It is possible for wet paint to comply with the lead limit, yet the paint on the final product, when scraped to confirm lead compliance, may contain unacceptably high amounts of lead. There are several possible contamination sources that could result in high lead content of paint/coatings on the final product. These include cleaning solvents used on spray mask or screen (some use leaded gasoline), spray mask or spray gun containing residue from previous (leaded) paint, rust (on mixing tools, stirrers or brushes as well as on the wet paint cans or other paint storage containers), leaded solder used on paint storage containers, and additives to the paint such as thinner.
There is a similar potential for contamination of plastic pellets. Additives such as flame retardants, color pigments and plasticizers can all affect the lead content (or phthalate content) of the final molded component. For example, when Europe first introduced the ban on phthalates in 1999, several “phthalate-free” materials were tested and found to contain phthalates, since they had been molded on machines previously used for standard plastic, which contained phthalates. The mixing machine and storage containers, as well as the grinding machines and mold release agents, are all potential sources of contamination.

When employed effectively and judiciously, component testing can reduce costly, redundant testing and provide an optimal solution to manufacturers and importers. Toy manufacturers and retailers should carefully evaluate all of their options and develop a component testing program that both meets the CPSC regulations and ensures the safety of their toys for the consumers who play with them.

Recalled Products

Mid-December 2009 - January 2010

St. Martin’s Press, New York, recalled approximately 204,000 Big Rex and Friends cloth books because a red plastic dot sewn into the book contained high levels of lead.

Jide Trading, Commerce, Calif., recalled approximately 2,100 Military action figures because surface paint on the toys contained high levels of lead.

OKK Trading, Los Angeles, recalled approximately 22,000 “Action Team” toy dart gun set because of an aspiration/choking hazard. The recall followed the death of an 8-year-old boy who inadvertently swallowed a dart, blocking his ability to breathe.

Kendamaspot, Redmond, Wash., recalled approximately 300 Wooden Skill Ball toys because surface paint coating on the balls contained high levels of lead.

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