Here's a little more clarification on the whole "reasonable testing program" thing:
"CPSIA section 102 provides that a general conformity certificate for lead content can be "based on a test of each product or upon a reasonable testing program." The Commission staff has previously indicated at several meetings that a "reasonable testing program" for lead content: (1) does not require third-party testing; (2) can be based on XRF technology if that technology is used in a reliable manner; and (3) if the manufacturer is confident in the results of lead tests done on components, does not necessarily require tests of the final product. For example, a finished piece of jewelry in which all of the parts (including the charms or beads, the chain or string, and the clasp, etc.) have been tested for lead content would not necessarily need to be tested as a final product. A manufacturer could issue a general conformity certificate based on the test of the component parts of that finished piece of jewelry so long as each part complies with the limit of "600 parts per million total lead content by weight for any part of the product," and no lead containing additions were made to the product during the assembly of the parts (for example, by the use of solder to join parts)."
Quoted from page 2 of this:
http://www.cpsc.gov/library/foia/advisory/323.pdf
