Let's compile a list of suppliers who test!

[#1]

Let's help each other out.

I am hoping that I can rely on the supplier's component testing of the fabric, buttons, thread, velcro etc. I realize that the law is not written this way, and I am supposed to redo it on the final product, but I am hopeful for an ammendment. In which case, I want to have all my ducks in a row.
Today I was chasing down numbers of suppliers. What a headache! All I got today was that my buttons are tested and OK for children. Great...I can make something out of buttons only?
Phone numbers and a person are rediculously hard to find. If this law does get changed, do you think that the suppliers will make it easier to get this information???? I have spent the WHOLE day on it!!!!! Anybody out there who has actually gotten a hold of person and knows some numbers to call would be greatly appreciated. I can't even figure out who makes a ton of my fabric because I bought them at Joann's who doesn't mark the bolt. Even the manager couldn't find it for me!!! How sad is that? Even if I knew of a couple of fabric makers that tested, that would help, because at least I could use them. I would just switch fabrics to companies who have tested.
I need information on:
Beads (people who bead in CA, how do you get this information????? I know you have to have it by law.)
Velcro
Cotton Fabric
Ribbon (anyone gotten a hold of Offray?)
Buttons (I did get a contact here who is emailing me the cert)
Elastic
Felt
Fleece

Let's help each other out. Don't be stingy? Who did you call? Who was helpful? Who wasn't? It would help us all out greatly!

I'll go first:
Buttons:
I got a hold of Favorite Findings and La Petite Buttons.
The website is www.blumenthallansing.com
I found a link for phone numbers and I called the rep in CA, Carlos Dashti, who actually answered. He said that the line Favorite Findings (sold and Walmart and Joann's) tests because it's used on children's items. He was happy to email me the results. His number was (213)400-2929. They have other reps for other areas on there too under the contact page.

[FayeMaloneDesigns]

You don't need the vast majority of fabrics, and textiles tested. When reading any of the threads on this forum, check the dates. Some of the longer ones started way, way back, when this law was first hitting us in the faces. In the beginning, everything was forbidden. Fabrics had to tested, including thread. Then they said undyed fabrics were okay. Then after a while dyed fabrics were exempt. So sometimes you are better off to start near the in the middle, or near the end and after you understand then work backwards. But, check the dates, You can be readin something that says may, but it is may 2009.

[Former_Member]

FayeMaloneDesigns says:
You don't need the vast majority of fabrics, and textiles tested. When reading any of the threads on this forum, check the dates. Some of the longer ones started way, way back, when this law was first hitting us in the faces. In the beginning, everything was forbidden. Fabrics had to tested, including thread.

Thank you! This makes perfect sense! I will double check dates!

[Former_Member]

Wow, thank you soo much for your supplier blog! I need to ask though, as I think I may have missed it: Say we take cotton material and make a bow, and add a button. What do I have to do? Anything as of right now?

I know this could change in 2011 though. How about snaps? Say I make a bib and use a snap and minky fabric. Do I hacve to test the material or have a tag on it?

Your blog has now helped me cross a HUGE item off my list of "things to do".

BTW, does anyone know how the new laws affect people who do craft shows? I am going to be doing some in the next few months.

[Former_Member]

angelbabyz,
The law affects everyone selling or donating children's items equally. It doesn't matter if you're a volunteer knitting newborn caps for the local maternity ward, a parent trying to make ends meet by trading up outgrown clothing for a bigger size at the thrift store, a homeowner clearing out the not longer used toys for a yard sale, a hobbist making money from your craft for more supplies, or even a fully registered business, if there are items for or marketed to children under 13 involved in the donation or transaction then it must meet the current CPSIA standards and provisions.

Snap and buttons used on a finished product primarily for children under 13, even during the stay of testing, do need test results either in the form of a actual lab testing report or a GCC /COC that gives the lab name and the lead results in PPM. The stay is about having only the government pre-approved 3rd labs doing the testing, you still need to know that the components used or the final product is below the allowable limits but you can use any recognized professional testing method or supplier in house testing to prove it while the stay is in effect. The stay of testing and the exempt raw material list does not affect the tracking labels if the finished product is for a child under 13 it needs the tracking info, nor does the stay & exemption list absolve an designer, assembler, or manufacturer from doing small parts testing/labeling, or phthalate testing on types of products that require them.

Here's some reading to get you started on understanding the CPSIA.

CPSIA guidance for small businesses/crafters includes a quick look guide Table : B exempt raw material list
http://www.cpsc.gov/about/cpsia/smbus/cpsiasbguide.pdf

The current overview of the "final" determination of raw materials for exepmtion
http://www.cpsc.gov/businfo/frnotices/fr09/leaddeterminationsfinalrule-draft.pdf

Info on a workshop to be hosted by the CPSC on testing and certification.
http://www.cpsc.gov/library/foia/foia10/brief/producttesting.pdf

Tracking labels
http://www.cpsc.gov/about/cpsia/sect103policy.pdf

CPSIA's FAQ page
http://www.cpsc.gov/about/cpsia/sect103.html#103q8

The main CPSC website
http://www.cpsc.gov/

The CPSIA main website
http://www.cpsc.gov/about/cpsia/cpsia.html

The CPSC's age determination guideline http://www.cpsc.gov/BUSINFO/adg.pdf

A timeline from the CPSIA http://www.cpsc.gov/about/cpsia/rulemaking.pdf

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.pdf

Even non-metal components must be tested using destructive digestive testing read more here http://www.cpsc.gov/about/cpsia/CPSC-CH-E1002-08.pdf

Small Parts Regulations Summary http://www.cpsc.gov/BUSINFO/regsumsmallparts.pdf
Small Parts labeling
http://www.cpsc.gov/BUSINFO/label.pdf
Maybe some one else has a link to a plain english version of the small parts regulations, but these 2 links are the best I have.

For fiber & fabric based products there maybe additions laws & regulations that need to be followed under a seperate government agency known as the FTC (Federal Trade Commission).

FTC Labeling requirements
http://www.ftc.gov/bcp/edu/pubs/business/textile/bus21.shtm#covered

[Former_Member]

So say I buy all my materials from suppliers that provide me with a certificate that they are CPSIA compliant, do I still have to have my items tested?

So say I make a bib that I buy from a manufacturer that has a certificate of testing/compliance, add a button that I bought from a manufacturer/supplier that has a certificate of compliance and added a ribbon that I bought from a manufacturer/supplier that has a certificate saying they are compliant....do I still need to have it tested?

Is there any way this law is going to change in some way that helps us stay in business( seeing how some things seemed to have changed since the initial notice of the law...I read that here somewhere. First it was ALL fabrics then some fabrics etc need testing) because at this point, I am not seeing myself staying in business long. i can't afford testing for 1 bib out of the 10 I make in a batch everytime I make a batch!

Something has to give!

[Former_Member]

I meant to say "Say I make a bib with fabric from a manufacturer that has a certificate of testing/compliance".

[Former_Member]

I meant to include this in the previous post

An update on the stay of 3rd party testing
http://www.cpsc.gov/cpscpub/prerel/prhtml10/10083.html

It explains the current use of supplier provided test certificates or GCCs or use of private lab component testing instead of final product testing.

Many labs are charging their testing fees based on the number of components used in a finished product and need as many samples of the finished product per batch as there are components that went into it's making. basically for me that means for a pair of earrings I would need to send the lab at least 4 identical pairs per batch minimum, one for each component - fishhooks, jumpring, headpin, and bead, and if I add anything more like a second color bead then I need to send additional samples. I could also choose to get the components all tested seperately, many of my supplies come in packages of 144 or more, then make copies of the test reports and attach them to the GCC I need to issue for each different design so I don't have to make as many of a single design (& lose them to final product testing), this will help out specificaly when I do an OOAK item as a special order. So if you can get the supply manufacturer to give you the info already or choose to have your componments tested before assemble you can significantly save on your testing costs, especially if the raw materials are spread over many designs.

[Former_Member]

So you said: "So if you can get the supply manufacturer to give you the info already or choose to have your componments tested before assemble you can significantly save on your testing costs, especially if the raw materials are spread over many designs."

But if I have proof of testing and passing, for each item I use, do I STILL need to have the final product tested? I have read sooo much tonight at that website, it's unreal nhow your brain swims. Thanks for answering this for me.

[Former_Member]

Anybody know about plastic buckles and clips? Like for use with shopping cart covers? It seems like they'd need to be tested but I haven't come across any info yet.

[Former_Member]

angelbabyz,
As the component testing guidance is written currently, if you can get all the testing info for non-exempt components that are used in a final product and tie those test reports or GCCs to a specific finished products then you don't need additional testing done on the final product. But if there is just 1 component that you do not have the correctly formatted testing info on then you either need to test that specific component at your expense or have the entire finished product tested.

Remember that the component testing guidance and exempt material list can be overturned without much noticed as it is not an actual part of the signed law, but an interpetation by the CPSC as what consitutes a reasonable testing program. So sign up for the e-mails from the CPSC concerning the CPSIA to keep upto date on what is going on.

[Former_Member]

marking

[Former_Member]

Thank you JewelrydesignsbyME. I think that is the best way for me to go at this time, use fabric and items that are already compliant in making my bibs, blankets and such. I will sign up for the newsletter there, good idea. Thanks again.

[Former_Member]

yes, and make sure that you use the blog to contact these suppliers, yourself, and get emails addressed to you, for your specific items. some of their items are not tested, some are.

and some of them send out GCCs that have your name on them.


now that we are further along, i plan to contact the companies again and see what kind of info they provide.


and fabric is included in the blog for exactly the reason jewelrydesignsbyME covered... in the very beginning, it was proposed to test everything. and those of us using textiles were enraged. we thought we were going to be forced to test a product that has no risk of either toxin.

it took months, and letters, and calls, and emails, and blogs... and meetings, and noise before natural materials and textiles were exempt.

[Former_Member]

Thank you DIYsockmonkeys.

So just a few more questions:

1. Do I still have to tag my items if I use ALL compliant materials?

I noticed that not all items from compliant suppliers are compliant. I have been very careful when deciding what I will be ordering. I hope that the list and the items these suppliers carry gets larger as far as more of their items being compliant.

2. Doees anyone have a Facebook page for this cause? I would be happy to spread the link around!

3. How about items we use to package our items(make our items look nice when getting them ready to ship them)? Things like colored/shiny tissue paper, ribbons, business cards, little safety pins that we attach to our paper tag that shows our business name on etc? Do they have to be compliant?

I want to thank you DIYsockmonkeys and everyone else that has made allot of noise, sent letters and made their voices heard. I'm going to start making my voice heard more. I just found out about all this recently.

I have signed a petition I found online and am trying to find out who I need to contact in my state to make my voice heard also and am passing on the word.

I emailed someone on a few craft shows and they weren't aware of the changes, it kinda sounded like, so I emailed them a link on this situation. I sure wish there would be a bit more leniency. I do understand safety and have kids of my own and daycare kids I care for. I would never want to see a child harmed, but somethings could be done that are overkill.

I do hope that they give us a bit more relief then they have. Is there any chance?

[Former_Member]

angelbabyz,
I'll try to answer some of the questions, but I do invite others to chime in with their interpetations

(1. Do I still have to tag my items if I use ALL compliant materials?)
Yes the CPSIA label is for tracking purposes if in the future there is ever a question or a concern about the entire product or even just a component used in it the government wants the general public to be able to match that info with a alert notice. Though many Estians could contact the customers directly about a recall or alert some of the purchases are mayhave been given as a gift or when outgrown passed on to someone else.

(I noticed that not all items from compliant suppliers are compliant. I have been very careful when deciding what I will be ordering. I hope that the list and the items these suppliers carry gets larger as far as more of their items being compliant.)
It's always best to contact the supplier or distributor directly to get the most upto date information or testing certificates.

(2. Doees anyone have a Facebook page for this cause? I would be happy to spread the link around!)
There are several, you will need to decide which one fits your philosophy best
http://www.facebook.com/search/?flt=1&q=CPSIA&o=69&s=0 there's another one at Ning Network http://cpsia-central.ning.com/profiles/members/#
There are other groups outside of the social networks like the Handmade Toy Alliance http://www.handmadetoyalliance.org/ , Learning Resources Blog http://learningresourcesinc.blogspot.com/ , and The Fashion Incubator http://www.fashion-incubator.com/


(3. How about items we use to package our items(make our items look nice when getting them ready to ship them)? Things like colored/shiny tissue paper, ribbons, business cards, little safety pins that we attach to our paper tag that shows our business name on etc? Do they have to be compliant?)
If the packaged is meant to just be looked at as a pretty presentation then be recycled or thrown away and not meant to act as storage for the product then it does not need to have any certifications. On the other hand if the packaging is meant to be use to store the item when not in use then it needs a set of compliancy paperwork and labeling to be included with the finished product's GCC keep in your files. With either type of packaging the tracking information must appear there as well as on the product.

...

(I emailed someone on a few craft shows and they weren't aware of the changes, it kinda sounded like, so I emailed them a link on this situation. I sure wish there would be a bit more leniency. I do understand safety and have kids of my own and daycare kids I care for. I would never want to see a child harmed, but somethings could be done that are overkill.)
Just as in the case of a retailer leasing a space from a landlord the promoters of a show or fair do not need to know all the laws concerning a specific type of business or product being sold themselves. They just need to let the "renter" know that they should be following all the local, state, and federal laws that govern the types of selling they are doing. It's one of the reasons many craft show/fairs have a general hold harmless agreement that includes a statement similar to "...the crafter/artist agrees to abide by all applicable laws..."

(I do hope that they give us a bit more relief then they have. Is there any chance?)
Contact all your representatives both at state and federal level to let them know how this is effecting your micro-business. Many representatives believe that this law only effects a very, very small percentage of cottage industries and small manufactures while protecting a larger portion of the American population. Be as precise as you can on the hardships that the law, as currently written, is affecting your business and how it impacts other businesses and persons around you. Don't forget to offer positive sugestions, like that the lead and phthalate testing should be done at the supply importers or manufacturers level to trickle down to the final product not the other way around.

[Former_Member]

Thank you so much for the time you have both put into answering my questions. If anyone else has anything to add, please add away.

[BarkRiverBoutique]

This is a great thread! Marking.

[Peaceloveandkids]

marking, thanks!!

[Former_Member]

Marking. Great idea!

I worked for a large outdoor clothing/equipment company until last Nov. I was their snr. apparel designer/developer. I don't have much experience on the equipment testing end, but for apparel we relied mostly on component testing, and documented that very well. If each individual component passed the lead testing the company was satisfied that the overall product would pass. We ran into some communications issues with overseas manufacturers and vendors, but for the most part this component system worked. The company's legal dept. seemed to be comfortable with this (again, just for apparel). It was a huge pain (even for a big company). No one seemed to have a good answer when new issues would arise, and they would all the time.
The company pushed it's vendors to supply the testing info. In the outdoor industry it was beginning to be typical for suppliers to test their components and guarantee CPSC compliance. Companies wouldn't source with vendors that didn't test so basically the vendors were forced to prove CPSC compliance. (I would assume that to be the case in other soft goods industries as well.)
Now that I work for myself this effects me and my business differently, but I wanted to share my "big company" experience.
If I learn anything about CPSC compliance from any of my current vendors I will post it.
Thanks & happy selling to all.

[Former_Member]

marking :)

[Hannalah]

Not sure if these have been added but I haven't seen them on the blog--
Sophia's, a doll supply wholesaler, sells buttons, zippers and such and will provide COCs if you request them with your order. You do need a tax ID to shop there:

http://www.shopsophias.com/index.php?target=categories&category_id=323

Also, Oriental Trading Company is compliant (see their "safety" page), and Dill's buttons replied to me that all their buttons are tested and safe, except the ones with rhinestones. I haven't followed up on those last two to ask about COCs yet.

[Former_Member]

I really don't understand, why if a large company who can afford to do this testing, is already doing it, why we would have to do it again!? That makes no sense at all.

[Former_Member]

Rainbow, I don't think we have to right now. I think component testing is acceptable to some time in early 2011. Right now we may use tested or exempt items as materials and consider our finished products compliant. I don't know where you can find more on this, but maybe someone else does. Anyone?

[Former_Member]

Marking! :)

[JansWearableJoy]

marking