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.