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CPSC Revised Phthalates Test Method: Test Component Parts
The CPSC has issued a new testing policy for determining CPSIA phthalate compliance. It is, in my opinion, a more common sense approach than the previous testing policy. As we all know, section 108 of the CPSIA prohibits the sale of children’s toys and child care articles containing more than 0.1% of certain phthalates. In previous guidance issued by the CPSC, the agency had taken the position that this prohibition applied to the entire toy or child care article, and not to its individual components, and that the article be tested accordingly, as a whole. This meant testing materials that would never contain phthalates and, more concerning, allowed for the sale of toys that included components with high phthalate content, provided the whole toy did not exceed the 0.1% limit. For example, a plush animal could have a phthalate-laden squeezable nose, a component that a young child would certainly mouth, yet phthalate content of the entire product could be below the CPSIA limit as none of the other materials contained phthalates. The product would have been acceptable under the previous phthalate testing guidance.
With the new testing policy, however, this product would no longer be acceptable. CPSC is now interpreting the phthalates prohibition to mean that the sale of children’s toys and child care articles containing more than 0.1 % of the specified phthalates in each individual plasticized component part is prohibited. The impact of this new interpretation is two-fold: First, the concentration of phthalates would be calculated solely on the basis of the weight (mass) of the plasticized component part, rather than the entire article. Second, materials that are not plasticized would not require testing, although they still would be required to meet the 0.1 % limit on the specified phthalates.
To help companies determine how to test a product for phthalate compliance, the CPSC has provided two lists. One is a list of materials that may contain phthalates and would require testing, and the other is a list of materials that do not normally contain phthalates and would therefore not require testing (although compliance to the phthalate ban is always required).
Examples of materials that may contain phthalates and would require testing are:
· Polyvinyl chloride (PVC) and related polymers, such as polyvinylidene chloride (PVDC) and polyvinyl acetate (PVA);
· Soft or flexible plastics, except polyolefins;
· Soft or flexible rubber, except silicone rubber and natural latex;
· Foam rubber or foam plastic, such as polyurethane (PU);
· Surface coatings, non-slip coatings, finishes, decals, and printed designs;
· Elastic materials on apparel, such as sleepwear;
· Adhesives and sealants; and
· Electrical insulation.
Examples of materials that do not normally contain phthalates and, therefore, might not require testing or certification are:
· Unfinished metal;
· Natural wood, except for coatings and adhesives added to wood;
· Textiles made from natural fibers, such as cotton or wool, except for printed decorations, waterproof coatings or other surface treatments, back coatings, and elastic materials (especially sleepwear);
· Textiles made from common synthetic fibers, such as polyester, acrylic, and nylon, except for printed decorations, waterproof coatings or other surface treatments, and elastic materials—however, any textiles containing PVC or related polymers must be tested;
· Polyethylene and polypropylene (polyolefins);
· Silicone rubber and natural latex; and
· Mineral products such as play sand, glass, and crystal.
These lists are not all-inclusive, and there are still some questions regarding material testing. For example, do all surface coatings require phthalate testing, or just those that are applied to materials that require flexibility? But the new phthalate testing policy simplifies the testing process, eliminates the unnecessary testing of products that do not contain phthalates, can reduce the cost of testing, and better harmonizes the CPSIA phthalates regulations with those enforced by the European Commission and by the State of California. It is an example of the common sense approach that the CPSC seems to be taking, and I’m looking forward to further such guidances and interpretations as the industry continues to implement the requirements of the CPSIA.