CPSIA Question 2

Question 2: The conditions and or circumstances, if any, that should be considered in allowing third-party testing of component parts.

The conditions that should be considered in allowing component testing are if the actual components used in the finished product are the same as those that were tested. Provided that each component has not been chemically altered, or any additional raw materials are introduced into the finished product, then component testing should be allowed.

In fact, component testing would be superior to unit testing when one small component would be over the legal limit for lead. For example, the allowable limit is 600 parts per million for the entire unit. If the buttons used on a garment were over that limit, but there were only 2 used on a finished garment, that allowable limit would probably not be exceeded for the unit, but would be exceeded for the component. In this case, component testing would reduce the danger of a small component of the overall product being over the allowable limit for lead.