Art Prints and Testing (CPSIA). Anyone get an estimate or do testing yet?

[Former_Member]

I posted in another thread that I tried to get an estimate for testing on my archival cotton rag and 8 pigment inks (Epson).
His response was this:

"I am in receipt of your request and question regarding testing of the print materials. You are fortunate in that print; from what I am able to find out, is not included in the regulation for the lead base paint required testing and certification. You may want to do some further research on this, but this is what I am being told.

One reason being the expense of separation on materials when textiles are died, or colored. It gets very expensive to separate and test those items of that nature.

Please feel free to call me with any questions, concerns on this."

Now, I have not ever seen that prints are not included. What I AM hearing is that EVERYTHING is included (minus possibly OOAK and materials that are known to be clear). I think in the beginning there was some hope because they are wall hangings, but that has since changed.

My concerns are twofold:

First, can prints be tested for a reasonable fee?

Second, does pigment ink contain lead? It's reasonable to suspect it DOES because many paint pigments contain heavy metals (and I avoid using them because of this).

I don't want to waste money having my art prints tested only to be told they don't pass and I'm out $$ in more ways than one. I did put in a call to Epson and they referred me to the MSDS but clearly had no other answers since pigment mixtures are proprietary information and the FDA doesn't require disclosure.

Have you gotten your prints tested yet?

[Former_Member]

This is new to me.

I've been following the threads since I have a second jewelry/gift shop, and my sister sells primarily children's clothes and accessories, but it never occurred to me that wall art would fall under this law.

Although, I suppose if your work would strike the general public as intended for 12 and under, it might. Good grief. Such a PITA.

[JunkJournalsByJules]

Since im not in the art/prints business im not entirely sure why an art print or painting would need to be tested for anything. Last time i got a piece of art i hung it on the wall in a painting.. i didnt nibble on it.

[Former_Member]

I did put a call into the CPSA Small Business Ombudsman a few weeks ago and asked about fine art prints and whether or not they are included.
I'm not sure why anyone would give them to a child to chew on, but I also understand that a child could possibly rip a frame off the wall during naptime and have a snack.

I guess.

Okay, I don't understand it at all, but laws don't always make complete sense.

[Former_Member]

Ok, this is suppose to be humor, so ... ;p

Oh, my what will Willy Wonka do about his Lickable Wallpaper? Has anybody try to imagine what "Snozzberry taste like?
:~) giggle,giggle....

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I honestly do realize what kind of horror the CPSIA is causing people with their poor wording about lead testing in children products...

[Former_Member]

Very good question...I have been reading everything I can and am still getting no satisfaction. As someone who makes prints for children's room (NOT children themselves, yes there is a difference) I would hope that no one would give their kid one of my prints to chew on. Goodness!

[Former_Member]

I don't think that art prints will be affected by this law. It is meant to target toys and children's clothing and accessories. I sell some children's prints too, but I don't have to plans to do any testing.

If that were the case then all children's school supplies would have to be tested too...lead pencils would be banned! Can you imagine?

Let's not let things get out of control here. =)

[Former_Member]

There is actually a motion from book publishers for an exemption from the law, but currently they are included. Like nearly all products for children 12 and under.

The CPSC website currently says that "posters" are included in items that require testing.

Pencil "lead" is actually graphite and hasn't been lead for a long time now, but I imagine pencils as well as other items kids used will require testing.

[Former_Member]

Hoping someone sees this and has more to add...

[Former_Member]

I have no information but I'm curious about it. Geez, my kids chewed on books pretty regularly as babies....nothing like a little "pulped fiction"

[Former_Member]

Wow that's crazy. What a nightmare CPSC created! I cannot imagine how printing companies can prove that their products are "safe to chew on".

[Former_Member]

Isn't it ridiculous? PoshDots (Etsy seller who makes fantastic wooden letters) received confirmation that children's art is included and must be tested. As far as I know, nothing intended for a child under the age of 12 has been exempted. I have to hope that art will eventually be exempted as it is not for "use" by a child, but right now, everything I have read indicates that it is subject to the testing regs.

[Former_Member]

Well, I found this:

http://www.cpsc.gov/about/cpsia/faq/101faq.html

Does the new requirement for total lead on children's products apply to children's books, cassettes and CD's, printed game boards, posters and other printed goods used for children's education?
In general, yes. CPSIA defines children’s products as those products intended primarily for use by children 12 and under. Accordingly, these products would be subject to the lead limit for paint and surface coatings at 16 CFR part 1303 (and the 90 ppm lead paint limit effective August 14, 2009) as well as the new lead limits for children’s products containing lead (600 ppm lead limit effective February 10, 2009, and 300 ppm lead limit effective August 14, 2009). If the children’s products use printing inks or materials which actually become a part of the substrate, such as the pigment in a plastic article, or those materials which are actually bonded to the substrate, such as by electroplating or ceramic glazing, they would be excluded from the lead paint limit. However, these products are still considered to be lead containing products irrespective of whether such products are excluded from the lead paint limit and are subject to the lead limits for children’s products containing lead. For lead containing children’s products, CPSIA specifically provides that paint, coatings, or electroplating may not be considered a barrier that would render lead in the substrate inaccessible to a child.

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It IS rather confusing though. I don't in any way think my children's prints are intended for use BY children - rather the adults who decorate their children's rooms. And it sounds like the "printed materials" in question are those that would be regularly "handled" and not hung up on a wall. Sill, it makes me wonder...

Crap, now I'M going to start losing sleep over this along with everyone else.

[Former_Member]

But does that then extend to murals painted on a kid's wall? See it can keep going and going and going. It's crazy-making! I know in the end wisdom must prevail here.

[Former_Member]

Guess, I'd better change my "Children's Art" section to something else...whatever people decide to do with my art after they buy it is THEIR problem, not mine. People started telling me they were using my Happy Day prints to decorate their children's rooms and that's why I created a separate section for them, but I'm not going to "suggest" it anymore.

This just sucks.

[Former_Member]

It's inclusion of "posters" in that blurb from the CPSC that is concerning for all children's wall art. Do children "use" posters? No, right? Then why did they include them there? I believe I understand the rest of the statement (if you use paint and it becomes part of a substrate, it is not subject to regulations pertaining specifically to paint but still has to be tested if it's in a product for children), but I don't understand the inclusion of posters.

Here's another example... the CPSC has excluded packaging from the CPSIA because it's not intended for "use" by a child. Wouldn't a poster be the same thing? You might hang it in a child's room, but they're not going to "use" it.

Anyway, I'm rambling. Add this to my growing list of questions/frustrations about these regs.

[Former_Member]

Wonder what would make a good "substitute" category name instead of "ART...for Children"?

"ART...Whimsy"?
"ART...Nostalgic"?
"ART...Imaginary"?
"ART...Dream-Time"?
"ART...Just for Fun"?

Time to start brainstorming.

[Former_Member]

artistcs28-
Unfortunately, art that is deemed to be attractive to children is also included no matter what we call it.

[Former_Member]

Including books is ridiculous. (Well a lot of parts are ridiculous). I homeschool, maybe I need to let the groups we belong to know about the book thing - those homeschoolers know how to lobby, let me tell ya!

My daughter(5 years old) has 2 magazine subscriptions. I wonder if they'll just stop coming in March. . . ?

[Former_Member]

marking...I had no idea this may affect me.

[Former_Member]

Well "attractive" to children is highly subjective, is it not? While a lot of people do use my prints for their children's room that doesn't necessarily mean that's what they're intended for. Should I have to get my Dahlia prints and Bird on the Vine printes tested just because someone "might" want to put one in a child's room? Lots of people just like them cause they're modern art. I'm not particularly worried about my shop, since I don't cater mainly to children.

But I had been thinking about self-publishing a couple children's books and selling them in my Etsy shop someday. THAT would definitely be something that would be on the radar, I know. I wonder how publishers like lulu.com are handling this? Is it up to them or to the individuals who buy books from them to do the testing?

[Former_Member]

artistscs28 says:
Well "attractive" to children is highly subjective, is it not?

Yes, it is! They better start testing cell phones, car keys, digital cameras, flashlights, dry erase boards, and many other things because that's what my kids want to have all the time.

[Former_Member]

I got to mark this so I can follow it everyday, because it is really getting crazy.

[Former_Member]

lol. What about carboard boxes? Kids LOVE those!!!

[Former_Member]

It is very very subjective and therein lies the problem.
We are looking at a slippery slope if the powers that be (whoever that is) starts deciding which art is for whom.

My work has been purchased for adults for their own enjoyment as well as for nurseries.

Honestly, I'm just hoping someone around here has tested their prints or at the very least had an estimate done.
If they don't pass, then obviously I have to make sure my art is not even the slightest bit interesting to children or parents decorating kid's rooms.