Finally! The CPSC is Asking for Our Opinon on the CPSIA

[#1]

Here's the link to the PDF file which states that those who make and sell children's products should email them with a list of the items that you use and think do not inherently contain lead so that they can consider it and possibly make it exempt:

http://www.cpsc.gov/about/cpsia/leadlimitsfr.pdf

There is also a list of materials that they had determined to be safe to use and sell, but we need to make sure to add to the list, like Polyfil, or I don't know what else. They're leaving it up to us, so email them when you can:

Secl01Determinations@cpsc.gov

Another note: there's section that states that the CPSC believes that this new act will not substantially affect small businesses, which to me means that if you fail to tell them what materials you use so that they can exempt them, then it's your own fault.

So email them until they grow weary. I'm so glad to see the little people stand up to the giants :D

[Former_Member]

I assume your comments will be based on the section of the CPSC Request for Comments that reads "the Commission seeks comments on...[o]ther materials, which by their nature, would not exceed the lead content limits."

If this is the case -- and I hate to play devil's advocte here -- but how do we know the "other materials" you are mentioning do not, in fact, exceed the lead content limits?

[Former_Member]

my list: (I tried to think of more fillers but my brain froze up.)

wool fabric, wool, fibers dyed/printed or undyed / printed
cotton " " " " " ....
POLYFIL - Dacron- rayon- etc fill.
other stuffing/batting materials as determined.
acrylic and other synthetic fabrics/yarns colored or uncolored
safety eyes, felt, cardboard, paper, inks, dyes, paints (craft paints bought at
the craft/sewing stores is ALREADY supposed to be lead free.)

[judyelizabethsflock]

Thanks for this information. I e-mailed my list.

Judy Elizabeth

[chatnoirstudios]

Oh yeah, quilt batting....I think I'll wait to send my e-mail too

Oh crap celluclay, polymer clays and paper clay for doll sculpting too

Doll armature wire, I use galvanized steel some artists use aluminium

[Former_Member]

littlepinkposies says:

I am planning to write about non-toxic, acrylic craft paints - all of my domestically-produced acrylic craft paints are certified by the manufactuer (with MSDS certificates available to all consumers).

-----

very good. That something would have to be tested again after the mfr (you) present evidence (info from paint mfr) is just too onerous. That's part of the point of the original paint certification!

[Former_Member]

I'm getting my list together and will return to email. Thanks for this link!

[Former_Member]

"Another note: there's section that states that the CPSC believes that this new act will not substantially affect small businesses, which to me means that if you fail to tell them what materials you use so that they can exempt them, then it's your own fault."

So you know, this section of the CPSC Notice is not commenting on the effect the new CPSIA law will have on small businesses. The analysis to which they are referring examined the impact the exemption of "certain materials or products from the testing requirements" would have on small business.

Or, said another way, it was determined small companies will not be adversely affected because these "certain material" have been given an exemption.

[Former_Member]

Yay! Thanks for posting this!

I sent:

100% cotton quilting fabric
eco friendly fiberfill (made from corn!)
cotton/poly blend thread

I hope they exempt this stuff!

[Former_Member]

burntchicken, these are all good points. As for knowing which items meet the lead requirements or not, I'm sure that it's better to be safe than sorry and just go ahead and email them. I'm glad to learn a different (better) interpretation for the section that you quoted me on. Along with this development, continue to send them emails, even if you're not sure. We speaking up so that we can receive proper clarification on this act.

[Former_Member]

I sent my letter. I hope it has some effect. How can they pass/enforce a law on Feb. 10th that is so vague?

[Former_Member]

Thanks! I"m marking to get back to later, I need to send in a list!

[Former_Member]

Made a list off of thigns listed in this thread, and closed with a statement that if the materials are purchased in the US, then it should fall upon the sellers to ensure that the materials are in compliance - not the end user.

[birdylegs]

I'm wondering if elastic would automatically be exempted if it is encased in a waistband. Same thing with stuffing and batting. There is some exemption for lead based things that are where children can't get to them. Although I don't think that a layer of fabric is any sort of barrier for lead, I'm using their own logic.

[birdylegs]

I'm laughing to myself about 10% of a generation of children wearing off-white, undyed fabrics held together with fabric ties. No color! No snaps! No elastic! No zippers! The other 90% will be clothed in their mass-market Hannah Montana/Star Wars outfits.

[Former_Member]

Thanks for posting this. My concern now is the professional grade steel beading wire. Any ideas?

[HipKidsTyeDye]

I just talked to Dr Hatlelid (not the right contact) but was very nice and talked to me for 20 minutes. They are SWAMPED with calls. She said more information is coming but couldn't say when - just that everyone is busy busy busy trying to deal with the onslaught of calls. Keep pushing for component testing. Push push push....

[Former_Member]

I believe that the info from the CPSC in the link states that cotton is excluded as well as other natural products. Note that is also say that people have 30 days to email.

[Former_Member]

30 days from the date the paperwork was signed which is today.

[Former_Member]

marking

[HipKidsTyeDye]

Yes cotton is excluded but "cotton fresh fromt he field" not cotton like we think of as consumers - the white cotton tshirt from Target is an unknown because of what could have been done to it during manufacturing. Wish I was kidding.

[Former_Member]

Hi burntchicken! Jennifer Taggert over at www.thesmartmama.com has already done a TON of XRF testing on a LOT of different fabrics, threads, etc, and even when she did find lead in a textile (some red prints), it was still nowhere close to what we are allowed by law. The only items that contained a lot of lead were the things you would expect to have lead...metal charms, paint, crystals, stuff like that. Here is the forum where she discusses what she's found: http://www.fashion-incubator.com/phpbb/viewtopic.php?t=3765
The CPSC is asking for stuff that either typically contains no lead or typically has much less lead than the restrictions, so I feel confident that we are all submitting totally safe materials for their consideration. Also, if anyone is not familiar with the NAM letter from the Nat'l Assoc of Manufacturers, it can be found here
http://www.toyassociation.org/AM/PDFs/Safety/CPSCPetition1208.pdf
and it explains how and why many materials should be exempted. Hopefully between them and us, we can get it done!

[Former_Member]

marking to email later as I need to prepare a detailed list.

thanks for the info!

[Former_Member]

a ray of sunshine and hope

[HipKidsTyeDye]

Dillybop - send the link from the XRF testing into for comments at the CSPC - we need all the help we can get.

[Former_Member]

Yep, white cotton tee from Target, cotton would have been bleached, so it would need tested. See silly this is?? Like anyone thinks a white cotton tee contains ANY lead, much less 300-600 ppm! Glad to know they are getting bombarded over there...at least we know SOMEONE HAS to listen to all of us!!!