leads me to post this straight from The CPSC FAQ page:
Q: Do all children's products require testing for lead or is it only products with
some type of surface coating? We sell products that are used in physical education
classes (e.g. hula-hoops) that are made from polyethylene and are not painted or
coated. Will this product require third-party testing and certification for lead
content under the new CPSIA?
A: All children’s products (as defined by the CPSIA) subject to the lead limit of the Act
will eventually require testing for lead, not just those with surface coatings. It is
important to distinguish between the rules that apply to lead paint and surface coatings
and the rules that apply to lead content. The CPSIA provides limits to the amount of lead
in paint and surface coatings and limits to the amount of lead in the content of the product
itself. Children’s products that are painted, or have surface coatings are also subject to
the lead paint limit, in addition to the lead content limits.
The reason I reprinted this here is because there is still confusion among small manufacturers on etsy and the like that make products primarily intended for children under the age of 12 that think this law doesn't apply to them. Clearly, from the above stated, IT DOES! There is no loophole, there is no exemption (right now), and there is no magic bullet. So far, the CPSC is taking comments regarding component testing, and also ruling on whether certain materials such as uncoated wood and natural fibers (undyed) should be exempt. They have not yet ruled on these questions. I think we should all devote ourselves to changing this law, not arguing amongst ourselves whether it applies or not. IT DOES. Enough said.
Tuesday, December 30, 2008
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.
_________________
Sunday, December 28, 2008
Inspired by a Pillow
To take a break from my CPSIA crusade, I wanted to write a little bit about how I am inspired. It really comes in all forms. Sometimes I'll see a shirt detail, something in nature, a colorful room, and each one of those things will get me thinking.
This time I was thumbing through Metropolitan Home on the airplane headed from Boston to Detroit. I spied that wonderful pillow you see pictured with the black and white polka dots. I love the strips of fabric and how the fabric was folded in on itself. Well, the rest just followed. Thinking on my stash at home I decided that Amy Butler's martini polka dot would be the perfect fabric on which to try this out. So, down to the workroom I went. I really wanted to leave the tucks un-sewn, but when that didn't work, I put plan B into action and topstitched each of the slanted pleats, and the result is what you see.
The gathered skirt has three horizontal growth pleats (mainly because I needed to shorten the length), but the real design feature is several criss-crossing pintucks that flirt around the bottom of the skirt. I like the way these mimic the slanted pleating on the yoke. Whoever said you needed to sew straight lines!
I love getting inspiration from other designers, but obviously my dress is nothing like the pillow, just my own take on it. I don't think any designer designs in a vacuum. There are always those who come before, and after all the human form hasn't changed much over the centuries. Thanks to Amy Butler, as her fabric lends itself perfectly to this style, and I can't wait to try it in different colors.
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.
Wednesday, December 24, 2008
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.
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.
CPSIA Question 1
The CPSC has requested comments from interested parties regarding component vs. unit testing and supplier provided certification. I'm going to take these question by question, even though many seem to be redundant. Please feel free to use my responses as part of your own, but I do think the more varied the verbiage the better. If they hear from many of us in our own voices, maybe they will actually listen.
On to the questions:
Number 1: How the risk of introducing non-compliant product into the marketplace would be affected by permitting third-party testing of the component parts versus of a finished consumer unit.
The only risk that would be introduced into consumer goods by component testing versus unit testing would be if a manufacturer substituted a different component after the component testing was completed. Say for example a certain trim was used in the prototype and the testing was completed on that particular trim. That trim then became unavailable for production and a different trim was substituted for the production run that was similar, but untested.
Similarly, if the manufacturer embellishes the product with appliqués, roller paints, iron decals, or other such embellishments, and did not have these components tested previously, there might be a chance of introducing non-compliant components.
However, a manufacturer should be allowed to permit the certifications from suppliers for the unaltered component parts, and additionally test those components for which no testing has been performed. Then that unit should be deemed sufficiently tested. Provided the manufacturer tested each component that was part of the finished unit, and no substitutions were made, then no subsequent risk would be introduced.
On to the questions:
Number 1: How the risk of introducing non-compliant product into the marketplace would be affected by permitting third-party testing of the component parts versus of a finished consumer unit.
The only risk that would be introduced into consumer goods by component testing versus unit testing would be if a manufacturer substituted a different component after the component testing was completed. Say for example a certain trim was used in the prototype and the testing was completed on that particular trim. That trim then became unavailable for production and a different trim was substituted for the production run that was similar, but untested.
Similarly, if the manufacturer embellishes the product with appliqués, roller paints, iron decals, or other such embellishments, and did not have these components tested previously, there might be a chance of introducing non-compliant components.
However, a manufacturer should be allowed to permit the certifications from suppliers for the unaltered component parts, and additionally test those components for which no testing has been performed. Then that unit should be deemed sufficiently tested. Provided the manufacturer tested each component that was part of the finished unit, and no substitutions were made, then no subsequent risk would be introduced.
Subscribe to:
Posts (Atom)
Posts
