CPSIA info for ABC Blocks...Help please!!

[beebles]

Hey everyone...
I've been reading through the etsy forum and other sites and the info is just not inputting into my brain!! Please if anyone could give me some info on what exactly I need to do for my ABC blocks, I would be so grateful.
This is one of the sets of blocks I make
http://www.etsy.com/view_listing.php?listing_id=36680459

I have a compliance letter from the glaze company, but know I will need to get these 3rd party tested... I contacted one for info, but never heard back. I believe the wood block I use is exempt, so would the testing be for the remaining items used to make them? Do I have to put a label on one of the blocks directly or can it go on the box they come in ( that is what I have always done).

Any info would be great guys!! Thanks so much!!

[Former_Member]

I think the actual wood block is exempt if it is unfinished...it's once you start adding to it...that's when it becomes a nightmare! I think oyu will need to have your paint and glaze tested...EACH color and each type of glaze! Since you sell them as a set I THINK you will only need to put a tag/sticker on one as well as in the box but I'm not sure about that one....hopefully someone like LILGIRLCA, FayeMalone or JewelrybyME will chime in here....they are always super helpful!
Good Luck!

[FayeMaloneDesigns]

You can put a label on the box or bag that the blocks come in. Is it a permanant box for storage or a cardboard box like for shippping? If it is a permanant box or bag, then that also must be "lead free"

Lead in paint must be tested for now, and must be less than 90pmm. Could the glaze have any phthalates (plasticizers)? If so then they need to be tested for those also.

You say you have a compliance letter for the glaze. Is it just a letter from the company that says "we are Okay", or does it list the actual test results from a registered 3rd party lab?

Also, you have misleading wording and tagging for age appropriateness. In your "rockin" blocks you say for your rockin baby (or words to that effect) but you say age appropriate for 3+. 3+ are not usually referred to as babies, and you caution against mouthing age. In your tags you use both children and babies. Therefore you are marketing to babies (under 3) as well as over 3. So the cpsc would see a misappropriate age disclaimer.

If under 3 uses the blocks and they bite and scrape their teeth on the blocks will the glaze and paint come off? You may need to get durablity testing.

But, really cute blocks! Welcome to the world of CPSIA, and it's insanity!

[beebles]

PicCircus and Fayemalone, thanks so much for your input, I really appreciate you taking the time.
I recently added the age appropriate warning, so you are absolutely right about the wording.. I have to go in and change that around a bit.
My glaze compliance letter is one from their lab testing so includes all testing results and is ACMI certified... that is what gets me, if you use all materials that have been tested and certified in the USA, why should we have to test again. Also the blocks aren't painted, I use prints from original artwork that are adhered using non toxic glue, then glazed using non toxic glaze. The box is one that the blocks are stored in and that is what I put the label on.
So basically, I would have to get the blocks tested for each component used... blocks,print,adhesive,glaze and the box tested? And then durability test for the blocks? And this all needs to be done by Feb 10th or I can't sell them until I have done so correct?

Thanks again!!

[Former_Member]

beebles, Just to add to what Faye said already, your glaze must test at or below 90PPMs for lead plus certain other elements & compounds and there is no stay of testing on product that contain glazes, paints, inks (except CMYK which is exempt), pigments, tints, and dyes (except for food grade and fabric dyes which are exempt) so your test certificates must be done by a lab that is CPSIA cerified and to the CPSIA's standard of testing. Also ACMI and the ASTM does not use the same test methodology that the CPSIA requires which is total lead by weight, though they do test for lead absorbtion into the body that the EPA and FDA employ. Also with the glaze being the outer most layer of the product and blocks being considered a toy you will also need the test results on the 6 restricted phthalates with the levels being under 100PPM.
Also you need to know what process is use to make the original art work. If it's printed on non-glossy paper by your home ink jet printer it should be exempt, but if it's done in some other printing method you will need test results on the inks or paints used. You may need the durability testing mostly to see if the outer glaze would scrape off during normal play handling to see if this layer would be exposed and if it is then you may also need the phthalate infomation on what ever inks or paints used to make the art work.
As for the glue you may not need to have test results since the CPSC may deem that the glue itself is inaccessable. Unfortunately it's hard to judge what the CPSC will see as inaccessable since the agency itself seems unclear about what coatings and finishes, beyond a plasitic casing for electronics, makes something impossible to access. Best to try to contact the CPSIA themselves to get a case specific ruling.
As for the labeling of the box, you are correct, if the product is too small to contain an effective tracking label then the packaging must have all pertainant information for tracking purposes under the CPSIA. The labeling portion of the law went into effect on 8-14-09 there is no stay to this and all products that where made on or after that date must have the tracking label. As Faye said if the box or bag is going to be a permanant storage for the blocks than it too must meet all testing standards under the CPSIA.
As for the wood block itself if it is not treated in any way by you or by the mill that cut and is considered a natural piece of cut wood then it is on the exempt materials list. No test or certifications needed, but if anything is added to the wood, like say you purchased a length of 2x2 from a home improvement store to cut down in to your blocks and the h i store sells it as pest resistant wood then you need to know if chemicals were added to the wood to make it resistant or if it's a natural accruing trait of that type of wood. If chemicals where added then you need the test results.
As for the Feb date since you are using what the government considers a paint (the glaze) there is no stay of testing you need the test results for lead plus 12 (I think) other banned substance in paints, and possibly for the 6 phthalates since the item is a toy before you currently even list the item for sale as well as the tracking information on the box.

As said before WELCOME TO THE INSANITY!

[beebles]

jewelrydesignsbyme....Thank you, thank you,thank you!!! Great info... I appreciate you taking the time to help me!!