The Labeling of Hazardous Art Materials Act (LHAMA) and ASTM D-4236, regulations may not be considered as correct testing for CPSIA compliancy since these regulations are geared towards detecting elements and compounds at levels high enough to affect the health of an adult.
The Art & Creative Materials Institute's (ACMI) voluntary testing and certification does not state what test methodology that they use. Nor do they state which agency's or private organization's levels of toxicity they are using as their benchmark. As example the current EPA testing methods and allowable lead absorption by the human body do not match or exceed the total lead by weight standard put forth by the CPSIA. So lead levels that the EPA say are safe for a child to be around are not the same as the what the CPSIA considers safe for a child's product.
Here are the two allowed testing methods under the CPSIA for determining the lead content by weight rather than what is possibly absorbed by a child.
Standard Operating Procedure for Determining Total Lead (Pb) in Children’s Metal Products (Including Children’s Metal Jewelry) found at
http://www.cpsc.gov/about/cpsia/CPSC-CH-E1001-08.pdfStandard Operating Procedure for Determining Total Lead (Pb) in Children’s Non-Metal Products read more here
http://www.cpsc.gov/about/cpsia/CPSC-CH-E1002-08.pdf If a component that you are using for a child's product is not exempt nor covered by the stay of testing you need test results using one of these testing methods to be compliant with the CPSIA. If the manufacturer of the component or the supplier is unable or unwilling to provide the test results using the allowed testing methods then you need to have either the whole finished child's product or the components tests to get the results in PPM for your files.
