Composite testing and the CPSIA

Some relief in CPSIA testing has been provided by the latest CPSC test method, released yesterday, for determining lead content in paint and other similar surface coatings (http://www.cpsc.gov/about/cpsia/CPSC-CH-E1003-09.pdf).

What is unique and exciting about the new test method is that, for the first time, CPSC is allowing for composite testing of multiple paint colors to determine compliance of each color to the lead paint ban (16 CFR 1303). What this means for industry is that, rather than having to test each unique paint and paint color on a product individually, the CPSC test method allows for combining more than one color in one analysis, thereby reducing the total number of tests required—and their associated cost. 

Composite testing must be done carefully to ensure valid results. STR and other Toy Industry Association member laboratories created a recommended composite testing protocol which was submitted to the CPSC on March 18. Critical factors in this test protocol, and in the CPSC test method, include number of paints in a composite (recommended limit is 3), weight of each paint (must all be comparable), and other technical variables such as equipment detection limits, balance tolerances, and correction factors.

One downside of composite testing is that the result may be inconclusive. Essentially this means that the test result may be too close to the acceptable lead limit (currently 600 ppm; in August it will be 90 ppm) to be able to confirm conclusively that each of the tested colors is below the acceptable limit and complies. In this case, each color would need to then be tested individually, at additional cost and testing time. But, in my opinion, the value of composite testing, especially for paint that is essentially “lead-free,” outweighs the occasional inconclusive test result. So talk to your lab about the new CPSC test method and decide what works best for you and your product. I, for one, am pleased to see the CPSC taking this reasonable approach.