3rd party testing already required for painted products?

[#1]

Is this true?

Under question 5 it says that 3rd party testing is
already required for painted products.
http://www.cpsc.gov/about/cpsia/smbus/sbguide.pdf

I thought XRF testing would be fine until August?

Did I read that right?

I'm so confused! I think I'll have no choice but to pull my kid's stuff(almost everything!).

[bobsandbits]

it is true. paints made in the usa cannot contain lead & are tested for lead. i've made loads of calls to all of my suppliers -- & i use latex paints in addition to acrylic.

[StoryBlox]

Oh, it's never (for me) been a question of whether the paints I use are safe/lead free - it's only been a question of whether the CPSC will interpret the new CPSIA law to say that any toy with paint on it (regardless of the paint or where it came from) is subject to the required 3rd party testing and coming after me for it.

Every time I make up my mind on how the CPSC is interpreting that law (it seems clear to *me* that it's not intended to say every painted item has to be tested), I read something else they publish and change my mind again. I'm not worried as much about the law itself as I am about the CPSC's interpretation and enforcement of that law.

[LeilasLoft]

I absolutely believe my paints are safe too.
I was referring to this statement.

"...if you use USA products you are golden!"

[Former_Member]

Question and if this sounds silly I am sorry, should be just have that info on file, or be sending info along to the consumer?

[bobsandbits]

good question. i wasn't planning to send it to the consumer. i have a link in my store taking people to my website page where i've posted this info (if they're interested). don't want to enclose it unless i have to cuz it's wasteful if it's not needed (but don't know).

[Former_Member]

I have my information listed on my shop page and in the auto letter that goes to them when they place and order. They will also get a small card the size of a business card with the order that says the samething.

[StoryBlox]

According to the legislation you have to have small parts warnings in any advertisements (so in your product descriptions, etc) if the item has small parts and isn't safe for small children.

As of August, we have to have specific labeling permanently attached to our toys (not on disposable packaging, but on the toy itself). Also, when the stay is lifted, we will have to have the 3rd party testing documented in a general certificate of conformity (gcc) that is available to our customers.

It can be published on a website, etc, rather than printed off each time, but each shipment of products to a retailer is supposed to contain information on where to find that GCC. I don't think we have to provide it for every customer, but it has to be easily findable should someone go looking for it (and we have to be able to provide it for the CPSC).

In any case, I don't think that is necessary until August on anything, or until the stay is lifted on the non-excluded items.

[Former_Member]

marking... need to read through the entire thread later...

[Former_Member]

Thanks, that makes sense to post it on the web site instead,

[StoryBlox]

Just a quick note, I switched a while ago to using Shellac on all of my children's products (it's a foodsafe coating that used to be used in candy before they moved to cheaper things), but I had some Varathane polyurethane sitting here so I sent them a message, got this back today:

"Varathane Polyrethanes will be nontoxic when fully cured and do not contain any leaed or phthalates."

[bobsandbits]

good to know. i'm finding some luck with polyurethanes too. there's one i posted earlier in the thread & i also learned that olympic's interior polyurethane is phthalate free too -- they even emailed me a letter stating that.

[Former_Member]

Storyblox I would say it is not safe to "assume" anything, as you know what they say about assuming...and it can also be expensive to find out you assumed wrong.

[StoryBlox]

Dees I had to scroll back to see which of my tons of comments you might be referring to, I'm assuming it was one a ways back about whether the MSDS statement was saying "lead/phthalate free" or not.

I did confirm later that those materials have to be reported in the MSDS, so if it's not reported there it's not in the products. Thus my earlier assumption was true.