CPSIA lead testing

[Former_Member]

I'm writing to every lab that the CPSC recommends for lead testing, to ask them for a price quote for testing my baby booties. I don't hold out much hope that Congress will do something about the CPSIA since they're all so busy deciding which of their cronies gets the next billion dollar bailout and picking out their clothes for the inauguration, but I'm hoping I can cover at least half my @$$ by testing one type of booties, if I can afford it. I will post when I get price quotes back, maybe tomorrow.

There was one lab that had prices on their website:
http://elementalresearchlab.com/sub_HO_TestKitOrder.htm
They said they offer a test for $65 but I got the impression they test water for lead, so I wrote to them to see if they can test products (the CPSC website said they could). If I hear back from them I'll pass along the info.

[MelanderDesigns]

You will need to test each completed unit in each SKU or color, size, and style combination from each batch or lot. Doing it one time, on one style, in one color will not work. Also keep in mind that you will have to do the lead test for each color in the bootie. If your booties have three different yarns, then each yarn will have to be tested for lead. Do the math and it will add up quickly.

[qbranchltd]

You can still do something about this - go here
http://www.etsy.com/forums_thread.php?thread_id=5943007

Tests are estimated to run $180 to $300 per ITEM per TEST. If the lot of your yarn changes you will need to test the same items all over again. There is no way that any of us can continue if this is enforced.

[Former_Member]

Oh, I know I'm not going to be able to test in full compliance with the law, but I thought I'd at least make a good faith effort to show that I want to comply with the law and would comply if it were possible.

I got one email back from one of the testing companies (on a Sunday even!) and he seemed a bit baffled that he'd been getting a lot of inquiries lately about testing cotton products.

[Former_Member]

Good faith effort won't mean anything if they "really" want to nail you. Hopefully they wouldn't do that though.

[Former_Member]

I have just opted to drop my children's burp cloths. That is the only thing I make for children. I buy the diapers from Wal-Mart, and buy my thread from a textile company, but who needs the aggrivation. My last several sets will be given to my adoptive daughters and friends as they give birth.

Colleen Mills
Mulvane,Kansas

[Former_Member]

Curious: IMO it can't hurt. And perhaps some of the labs will bother to explain to the CPSC that testing all these textiles is totally unecessary and a PITA! I think a "good faith" effort does count for something. What exactly that something is, I don't know. I'm not sure I'd go through with any testing yet--at least wait until we get some more real information from the CpSC. But for sure you're doing your homework.

[lilbritknits]

One thing I'm unclear on - when is the cut off date for sales - is it dec 22nd or feb 9th.- this is in relation to legally selling baby gifts.

[Former_Member]

Aren't the bulk materials you use tested by the manufacturer? If you buy your yarn, or whatever materials you use, you personally wouldn't be required to do the testing, right?

[lilbritknits]

Not true - you as the manufacturer have to test your product. And you have to test each one - they've made it incredibly complicated and expensive and impossible. I am going to have to stop making my baby gifts and will concentrate on my other products. - I've written my senator, and I'm urging everyone on etsy to do the same.

[Former_Member]

And what does this do for the upcycled, eco movement? I'm baffled at how to work without just dropping clients 12 and under...

[Dannielle]

I couldn't even begin to test. Most of my dolls are one of a kind and I use such a myriad of supplies (you should see my bin of embroidery floss and my quart jars of seed beeds!) that it's not even feasable.

[Former_Member]

If you want to try to interpet the law yourself here are some of the goverment links :
A copy of the actual law as it stands today: http://www.cpsc.gov/cpsia.pdf
The general CPSIA website : http://www.cpsc.gov/about/cpsia/cpsia.html
Standard Operating Procedure for Determining Total Lead : http://www.cpsc.gov/ABOUT/Cpsia/CPSC-CH-E1001-08.pdf
Original CPSIA FAQs http://www.cpsc.gov/about/cpsia/faq/faq.html#educational
Most recent updates to FAQs : http://www.cpsc.gov/about/cpsia/faq/newfaqs.pdf
How CSPIA effects exsisting inventory & by extension vintage, resale, & recycling of children's items :
http://www.cpsc.gov/library/foia/advisory/317.pdf
List of accredited labs for testing http://www.cpsc.gov/cgi-bin/labapplist.aspx BTW only 14 of the 71 are in the USA all others are overseas.

or try
http://thomas.loc.gov/
Then search:
H.R.4040
Consumer Product Safety Improvement Act of 2008 (Enrolled as Agreed to or Passed by Both House and Senate)


Here's links to write your district's congressperson and senate represenatives as long as your still a registered voter. Otherwise write directly to the CPSIA voicing your concern.

https://writerep.house.gov/writerep/welcome.shtml

http://www.senate.gov/general/contact_information/senators_cfm.cfm

http://www.cpsc.gov/cgibin/newleg.aspx

[Former_Member]

OK ladies and gentlemen, the first quote is in. Keep in mind this is for testing just one of my baby booties. If your products are different, this may affect the cost for you.

Applied Technical Services quotes:

The cost to analyze one of your samples is as follows:
1. Lead content $75/sample or color
2. Phthalate content $300/sample

These prices are for a turnaround time of 7-10 business days from the time we receive the samples and a purchase order/credit card number.

[Former_Member]

And the second quote is in, this one from Intertek:
Thank you for your interest in Intertek services. We can perform lead testing at our lab in Arlington Heights, IL and the price is $70.00 per surface coating or component.

That's two quotes now in the under-$100 range. Yeah it's spendy but maybe not as spendy as some of us thought, the figures I was hearing were in the thousands per test.

[littlegirlPearl]

keep in mind curiousworkmanship that if you change your colors, you have to re-test, and if you have different buttons on your booties, you'd have to test each component. While it may not be pricey for you, it will basically put me under. All that component testing adds up.

[Former_Member]

Oh, I have no intention of testing every color, size, and style. There's no way in hell I can afford that, it would be bigger than my annual sales volume. But I figure if I test one thing, then IF the CPSC gets around to me I can show them that they're barking up the wrong tree.

[Former_Member]

littlegirlPearl, I'm with you- I just can't possibly test all the supplies in even one item, even if the qoutes are coming back less expensive than most of us thought.

[Former_Member]

I've been going over the videos of the CPSC hearings, and my observation is that they have limited staff and would be very interested in enforcing this law according to its spirit (keeping lead components out of children's mouths) rather than its letter. It sounds to me like the CPSC would much prefer that for products unlikely to contain lead, that they can have some kind of assurance that these are not the leaded toys they're looking for. So I have a good feeling about doing one test and having something I can show them. Their own general counsel admitted on video that they were not wanting to go after 100% cotton T-shirts and were just looking for some kind of reassurance from the manufacturers. They're not thrilled with the law and with being charged with enforcing it.

That's just my impression from watching the videos. YMMV.

[Former_Member]

I was speaking to a friend who used to be in the children's apparel manufacturing business selling to the big box stores. She said that to comply with the laws (then) they would send a sample of a finished product to the labs for testing. The chemical process used for the testing essentially destroys the product. That's fine when you are making thousands of the same thing, not so for OOAK. Even if we tried to comply with the new laws, we couldn't! Does anyone know how the labs would do the testing?? I've read about people contacting labs to find out the costs, but has anyone asked about the actual testing procedures? Just one more tidbit that makes no sense in this whole mess

[LerayjessDesigns]

For a small at-home crafter, this is impossible. I don't want to give up plushies, but I'm afraid I'll have to.

[Former_Member]

I'll share what I've learned about the lead testing and hope it helps somebody.

There are three kinds of testing for lead. One kind is the home lead tests you can get for cheap. This has a chemical solution that reacts with lead to produce a certain color. But it only works on surfaces; if there's lead inside, it won't catch it. It is not destructive of the item.

The second test is X-ray fluorography or XRF. XRF is basically shooting X-rays at the thing and see if it "lights up". Remember X-rays can't see through lead, so if it finds that the X-rays bounce back, there's lead there. This is a non-destructive test that is great for houses because the equipment can be brought in to test. However, the test doesn't accurately show levels of lead, only the presence of lead. The CPSC is considering allowing the use of XRF as a screening tool to see if a product needs to be tested, but because the acceptable level of lead is so low (600 ppm decreasing over time to 100 ppm), XRF won't be adequately accurate.

The kind of testing I'm getting quotes on is a digestive test. Basically they stick the thing in acid and test the resulting goo for lead. This kind of test will detect lead that is hidden inside. The downsides of this test are that it completely destroys the object, and it is expensive.

Hope that helps!

[Former_Member]

I am just saddened by this whole situation...as I said in another thread, I was already planning on closing my shop due to wanting to spend more time with my children. I will just do it sooner. But for the record I am still going to buy from Etsy...I know emotions are running high - but it just seems that our fearless leaders are loosing sight of so much these days!

[PunkeyMonkey]

This was listed at one of the govt. sites regarding the new laws for Feb.
People here at Etsy are getting panicked and upset, and rather than looking for answers here from other sellers who may not know the proper information.
Call and get educated as to how the new law will effect your personal situation, products, etc.

For All CPSIA Inquiries
In the U.S., please call 1-800-277-3300

[Former_Member]

hi, I posted something about testing under my other shop The Twisted Cow.

If you are making a product and you will be making them in different colors and styles, then testing one item will suffice as long as they are made out of the same materials. So, if you make baby booties out of cotton, felt, and leather then as long ad you use the same material for that product line then you do not have to test each one.

hope that helps
Linda