Rob Wilson, of Challenge & Fun, and http://www.cpsia-central.ning.com, rented an XRF gun, and since his company is relatively close by, I took advantage. After a challenging 2 hour drive with my toddler in tow, I understand even more how truly challenging it is going to be to stay afloat after this law goes into effect. At any rate, I thought I would talk about the whole process of XRF testing.
I had both my current inventory with me, and lots of swatches of the fabrics that I have been using throughout the past year. I also had each and every trim, piping, rick rack, and embellishment that goes into and onto my clothing. Believe it or not, I had all of my buttons as well, and there is the rub. But more about that later...
Here is how it works. XRF, or x-ray fluorescence, is able to detect the type of material being tested, and also the heavy metal composition. Depending on how the user sets the parameters, one can tell how many parts per million (ppm) are in any given substance. You put the gun flat on the object, or use a small stand with a cover for smaller items like buttons, and pull the trigger. After about 30 seconds, it records the readings, and voila, pass or fail. It also gives the amounts, all the way down to less than 5 ppm.
All of my textiles and trims passed with flying colors, as expected. The manufacturer of my materials has told me as much, but it's good to know for sure. The buttons on the other hand were a different story.
The vintage buttons, understandably in some cases, failed in a big way. What was more surprising however was that none of the buttons I use are metal. They are all plastic, nylon, or acrylic. The problem seemed to stem from buttons that had any kind of shimmer, or a pearl-ized look. It seems the manufacturers of these buttons must be specifically adding lead to get a metallic look. The other interesting finding was that if one color in a style failed, then the other ones would too. The color of the button proved to be of no consequence, it was merely the presence of a metallic look that gave any prior indication of a failing grade.
The thing that was challenging to me was that not all the metallic ones failed, only a certain few. These are new buttons though, not vintage, and on first glance it is nearly impossible to tell which one might contain lead. So, my recommendation to others would be to make sure you are testing your buttons, and also to avoid shimmery styles. I obtain my buttons from a reputable distributor, but I did notice a disclaimer on their website for the first time last week. Yes, you guessed it, "not intended for use by children under 12". Big surprise...
So the good: all textiles passed, even vintage fabrics. The bad: A 5 hour round trip drive with a toddler, and 3 1/2 hours of testing...what drudgery! The truly hideous: I'm losing some styles of buttons I love. Alas, not worth the risk. Eventually, I'll post all the style numbers and manufacturers of the buttons that failed, so that you too can avoid these styles. If they end up sitting on the shelves long enough, maybe the button manufacturers will change their practices. Just maybe...
Showing posts with label component testing. Show all posts
Showing posts with label component testing. Show all posts
Thursday, January 15, 2009
Monday, December 29, 2008
CPSIA Comments, Question 5
"Whether and how the use and control of subcontractors would be affected by
allowing the third-party testing of component parts."
This is the hardest question for me, because I don't contract out, and have no experience with the manufacturing process outside my own basement. So here goes.
A quality control system would have to be put in place that may include randomizing testing and implementing stricter quality control processes. Instead of checking the first few from a production run, a manufacturer might pull and spot check somewhere down the production line. That way if the contractor has substituted a tested component for another, a check against the original components could be performed. In the apparel industry, this could be performed by a visual inspection compared against the original compliant components specified by the manufacturer.
As for toys, or other products, this might be harder to determine. Whether a certain paint has been swapped for another, might be difficult to tell without doing random unit testing. However, if you did do unit testing on one of the first few from the production run, and then later on a switch was made, unit testing wouldn’t have made that product any safer versus component testing. It really comes down to random quality control.
I welcome all of your comments to help me formulate these responses, as I'm pretty sure I'm not aware of many of the complicating factors that many businesses face.
_________________
allowing the third-party testing of component parts."
This is the hardest question for me, because I don't contract out, and have no experience with the manufacturing process outside my own basement. So here goes.
A quality control system would have to be put in place that may include randomizing testing and implementing stricter quality control processes. Instead of checking the first few from a production run, a manufacturer might pull and spot check somewhere down the production line. That way if the contractor has substituted a tested component for another, a check against the original components could be performed. In the apparel industry, this could be performed by a visual inspection compared against the original compliant components specified by the manufacturer.
As for toys, or other products, this might be harder to determine. Whether a certain paint has been swapped for another, might be difficult to tell without doing random unit testing. However, if you did do unit testing on one of the first few from the production run, and then later on a switch was made, unit testing wouldn’t have made that product any safer versus component testing. It really comes down to random quality control.
I welcome all of your comments to help me formulate these responses, as I'm pretty sure I'm not aware of many of the complicating factors that many businesses face.
_________________
Saturday, December 27, 2008
CPSIA Comments, Question 4
On to Question 4:
"Assuming all component parts are compliant, what manufacturing processes and/or environmental conditions might introduce factors that would increase the risk of allowing non-compliant consumer products into the marketplace."
There is no manufacturing process that has the possibility of introducing lead unless it involves introducing a new component that might contain lead, ie. solder. Simply heating, sewing, cutting, ironing, and the like, cannot change the chemical make up of the unit, and will not introduce lead if it doesn't already exist.
If however during the process of manufacturing, an untested component is introduced such as solder or a surface coating, then that might change whether or not the unit is compliant. But, the fact remains that if all the components have been tested, then processing those components will not alter the chemical compounds significantly enough to pose any hazard.
My husband and I laughed at this one this morning. Short of alchemy, or having a nuclear reactor in your manufacturing facility, introducing lead where none exists is impossible.
"Assuming all component parts are compliant, what manufacturing processes and/or environmental conditions might introduce factors that would increase the risk of allowing non-compliant consumer products into the marketplace."
There is no manufacturing process that has the possibility of introducing lead unless it involves introducing a new component that might contain lead, ie. solder. Simply heating, sewing, cutting, ironing, and the like, cannot change the chemical make up of the unit, and will not introduce lead if it doesn't already exist.
If however during the process of manufacturing, an untested component is introduced such as solder or a surface coating, then that might change whether or not the unit is compliant. But, the fact remains that if all the components have been tested, then processing those components will not alter the chemical compounds significantly enough to pose any hazard.
My husband and I laughed at this one this morning. Short of alchemy, or having a nuclear reactor in your manufacturing facility, introducing lead where none exists is impossible.
Friday, December 26, 2008
CPSIA Question 3
Forgive me if this is a tad incoherent, and replete with run-on sentences, but I wanted to get something down on paper before I headed to bed. Here is the next question that the CPSC is taking comments on regarding component testing.
The conditions, if any, under which supplier third-party testing of raw materials or components should be acceptable.
The conditions which supplier third-party testing of raw materials and components should be accepted is if the manufacturer using those raw materials does not alter them in any chemical way. For example, a fabric manufacturer tests each fabric for lead and it is under the allowable limit according to the CPSIA. The fabric manufacturer then sends a copy of the test results to the manufacturer of the children’s product, or has them available electronically. Provided the manufacturer of the children’s product does not chemically alter the fabric (painting, surface coating, etc.), then that supplier third party test should satisfy the requirement of the CPSIA. It would not be cost effective to retest already tested materials, and retesting would not make that particular product any safer for the child. If the manufacturer is cutting and sewing a raw material, and not altering it in any other way, supplier third party testing should be acceptable.
Moreover, the cost of testing already tested materials not only hinders business, but it is redundant and unnecessary. As manufacturers seek out raw materials that are inherently lead free, or have already been tested by the supplier and shown to comply in order to avoid costly testing, the likely result is that less lead will be introduced into the supply chain. The demand for supplies that have already been tested would likely rise. If a supplier cannot prove that his raw material complies with the law, then the demand for his product would go down, resulting in fewer raw materials that contain higher levels of lead.
In fact there are many European standards that already exceed regulations set forth in the CPSIA to date, and as such should be allowed as part of a testing program. Supplier provided certifications would dramatically lessen the economic impact on small businesses, and allow many to continue operations.
The conditions, if any, under which supplier third-party testing of raw materials or components should be acceptable.
The conditions which supplier third-party testing of raw materials and components should be accepted is if the manufacturer using those raw materials does not alter them in any chemical way. For example, a fabric manufacturer tests each fabric for lead and it is under the allowable limit according to the CPSIA. The fabric manufacturer then sends a copy of the test results to the manufacturer of the children’s product, or has them available electronically. Provided the manufacturer of the children’s product does not chemically alter the fabric (painting, surface coating, etc.), then that supplier third party test should satisfy the requirement of the CPSIA. It would not be cost effective to retest already tested materials, and retesting would not make that particular product any safer for the child. If the manufacturer is cutting and sewing a raw material, and not altering it in any other way, supplier third party testing should be acceptable.
Moreover, the cost of testing already tested materials not only hinders business, but it is redundant and unnecessary. As manufacturers seek out raw materials that are inherently lead free, or have already been tested by the supplier and shown to comply in order to avoid costly testing, the likely result is that less lead will be introduced into the supply chain. The demand for supplies that have already been tested would likely rise. If a supplier cannot prove that his raw material complies with the law, then the demand for his product would go down, resulting in fewer raw materials that contain higher levels of lead.
In fact there are many European standards that already exceed regulations set forth in the CPSIA to date, and as such should be allowed as part of a testing program. Supplier provided certifications would dramatically lessen the economic impact on small businesses, and allow many to continue operations.
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