The MSDS is made up by the manufacturer to give general information about how hazardous a product is and what to do if there is a leak, spill, contamination. They are made up when a product is introduced and are not changed unless/until the product itself is changed. A manufacturer can produce thousands of lots of the product and use the same MSDS for each of those lots. It doesn't show that each lot was tested for toxins. A certificate of analysis will show that a certain lot of a certain product was tested.
If a batch of fabric paint was somehow contaminated with lead because of a faulty ingredient in the paint, a certificate of analysis will show that but an MSDS won't.
Don't worry- I had never heard of an MSDS before I worked in new product development for a manufacturing company.
You can actually draw up an MSDS without testing the product, although that's not necessarily how everyone does it. You would use the ingredients in the formula, if those ingredients were considered flammable, toxic, or safe, and draw up the guidelines. Depends on the product.
If a batch of fabric paint was somehow contaminated with lead because of a faulty ingredient in the paint, a certificate of analysis will show that but an MSDS won't. ---------------------------
that's a really good point, and might have a lot to do with the final testing of the products and not the supplies.
which, still doesn't make sense at a level where i'm sewing socks in my home... but i see how something like that could be an issue where lead was used as an additive.
i don't use a whole lot of brands. i think it makes sense to have whatever documents i can get on hand... i feel like this is kinda good. i wanted to expand soon, i should know all this.
It certainly never hurts to have information on hand about the supplies & products you use in your work! MSDS's are good info. I just can't quite see the CPSC using them as proof that your product is lead-free, that's all.
That's what I want to know, Stacey. How the heck can I stay in business with all the testing required? I have to find a way to use already tested material. If an MSDS sheet won't tell me.... I am wondering though if the companies are really willing to test all of their batches. I mean, I am having trouble coming up with MSDS sheets on many of them.
Each batch for each product would have its own COA. Depending on the size of the manufacturing company this could get to be a huge job to put them all up online. We would get a copy of the raw ingredient COA when it was received in our warehouse, and keep it on file. Any COA's that we generated we would keep on file and send out on request. Not all products we made needed COAs. If we were making dog shampoo, we don't need to certify that there is any certain level of any certain ingredient in the shampoo, so we wouldn't generate a COA. For our FDA and EPA approved products, all batches have to have a COA. I don't know how this translates into supplies such as beads and fabric. We manufactured animal health products for pets.
some of our manufacturers use no lead, at all, in any part of their processes, i wonder how that effects the regularity of repeating the testing process on their end.
sugarplumbtree says: That's what I want to know, Stacey. How the heck can I stay in business with all the testing required? I have to find a way to use already tested material. If an MSDS sheet won't tell me.... I am wondering though if the companies are really willing to test all of their batches. I mean, I am having trouble coming up with MSDS sheets on many of them.
It's an expense for a company to test their product batches and develop COA's on them, so not all items would necessarily have testing done on them because it drives up the price of the item. Especially if the items are not necessarily just used in children's products. Maybe some people use a certain fabric for making diaper changing pads but most people use the fabric for things for adults. So the company that makes the fabric might not be super-motivated to go through a bunch of expensive testing just for the 1% of customers that use their fabric for baby stuff. That's probably one reason that the law was written to put the burden on the person/company that makes the final product intended for consumer consumption and not on the supplier.
the next hurdle: How do you know what batch your particular item came from? Meaning: If I buy black Coats and Clark thread at my local store, how do they know which batch it came from to even pull that for me? This is just seeming monumental at the moment. I can't see them wanted to email me batch information every time I go to the store. I guess they company would just have to post somewhere that every COA they have on file passes, and that would then include my batch????? This is just getting trickier and trickier......
I gotta go to bed, but every bolt wouldn't necessarily need its own COA because the manufacturer might make 100s of bolts in one batch or lot.
Depending on how the laws/regulations/requirements are written is what tells the manufacturer how often to test. Some things are every single batch, some things it's not required at all.
sugarplumtree- when you buy cold medicines or neosporin ointment and stuff like that at the drugstore, all those will have a lot or batch number printed somewhere on the label or bottle. Those are traceable.
Not all products are traceable like that. I cannot imagine that fabric, bead, and ribbon makers have been labelling each individual lot of product they make because it's expensive to keep records like that. And never before has there ever been a need to keep track of individual items like that.
I just got the MSDS for MinWax Polycrylic. States right here that the lead Limit is 600 ppm in dry film! Isn't that the amount that will be required come August?
i wanted to bring this back up, because it seems that a lot of suppliers that DO have lead content are referring to their MSDS sheets to show that they are still compliant.
which leads me back to my question:
if lead is considered a toxic material, shouldn't it be listed on the MSDS sheet, IF its in the product?
the hosiery technology center's presentation was considerably interesting to me, not because my product is made from socks, but because their expert witness collected 3000 something MSDS sheets from the industry because he said "if lead is in the product, it will be on the MSDS."
