CPSIA and The Labs

The CPSIA has placed additional burdens on toy manufacturers, by adding requirements such as lead content and phthalates and by mandating third party testing. One outcome of the CPSIA requirements is that quality assurance laboratories such as STR have seen a dramatic increase in their testing business. Some companies suspect that labs have helped push this legislation through as a way to increase profits! This is simply not true.  STR and other major laboratories have actually been working to reduce redundant testing and to consolidate testing where it is practical, without adversely affecting either the safety of the product or the CPSIA requirements.

For example, in February 2009, STR spearheaded a meeting with the CPSC and three other major laboratories to discuss CPSIA requirements as they relate to testing. Topics discussed at this meeting included Component Testing and Composite Testing, with the labs recommending both (where appropriate) even though CPSC acceptance would mean that reduced testing would be required. 

Component testing would reduce or eliminate redundant testing of identical components. Rather than performing full testing on all components in each individual SKU, if certain components are used in more than one product AND there is sufficient traceability that confirms the components are identical, component testing would allow a component to be tested once and to transfer those results to subsequent items that use the same component without testing the component repeatedly. See http://www.playthings.com/article/CA6647282.html.

Composite testing means combining more than one paint or material in one chemical analysis, rather than testing each paint or material individually. Again, there are specific parameters that must be applied to this testing to ensure that the test results accurately reflect the amount of chemicals in each paint or material, and that they can be certified as complying to CPSIA limits.  But it can be done – which leads me to the second example.

As some of you may have noticed, there was (very briefly) a test method published on CPSC’s CPSIA site on March 26 that defined a procedure for composite testing for total lead content in paint. The method was quickly pulled from the site as it had been inadvertently posted before obtaining full clearance, but Test Method:  CPSC-CH-E1003-09 was re-posted on April 28. This CPSC composite test method for lead in paint (and other similar surface coatings) is a direct result of the recommended test procedure provided by TIA’s Working Group to the CPSC on March 18, entitled “Compositing Acceptance Method for Lead in Surface Coatings.”  The TIA Working Group consists of several TIA member laboratory experts who work cooperatively to assist and speed the CPSC’s efforts in developing testing protocol.
 

Ultimately, it is the labs’ job to test for compliance to the CPSIA, and if this means redundant testing, we have to do so. But we are working with the CPSC and TIA to develop a reasonable testing program rather than indiscriminately test everything and add to the financial burden that the CPSIA has placed on toy manufacturers.