One more question on CPSIA

[HoldsIt]

So I'm trying to understand the new stuff that will go into effect in January. I get that it will be first party testing allowed on components. Yippee! However, I can't figure out if buttons that are covered are considered accessible by children. I also need clarification on something... if I have to have a component tested on my own, I need to have it tested every time I get a new order from that supplier... correct? If that is the case, I'm going to order a gazillion of them at one time!

[Former_Member]

You're a little off on your terminology, I'm hoping you're actually referring to supplier provided testing certificates of testing done by a 3rd party lab, meaning GCCs or COCs or actual lab reports.
first party testing = in house testing done by the finished products manufacturer vetted and approved annually to CPSIA standards

As for your 2nd question about covered buttons if the entire button including the shank and loop are covered completely then the button is considered inaccessible to the child, but you will need to show the covering is exempt or an already tested supply. But if any metal or plastic part of the button is exposed even if it's the underside then the government can rule that you need to either test it at your own expense or obtain supplier prodived test information.

As for having your own testing done, yes every time you have a different batch or lot number on a supply then you need a new test report. In some cases it is possible to place orders at different times and still recieve the same batch or lot # on a supply. But it could just as easily happen that you place one massive bulk order for a supply and wind up with 2 or more batch/lot # in your single order each needing it's own testing.

[HoldsIt]

Yes, I mean testing done by the supplier and providing me with a gcc vs. me having to test the items at an independent lab. I understood that to be first party testing whereas testing by the final manufacturer of the kiddie item would be third party testing. But after reading all this stuff my eyes glazed over and crossed so not surprising I got it wrong.

No part of my button is exposed. It is all covered by exempt materials and permanently attached. So permanent that if I make a mistake I have to toss the whole thing in the trash!

[FayeMaloneDesigns]

There really isn't any 1st party testing. Some manufacturers have been approved to have 3rd party firewalled testing labs in house. Meaning that no one in the actual manufacturing process or in management has control/influence over the testing lab, nor does anyone that will be receiving the product for example Walmart/Toyrus. It is, the lab, essentially a seperate entity, just housed within the manufacturing facility. This saves Mattel for example time and money.

Since no part of your button is exposed, then I guess you may be safe from testing, but if you can get a GCC , you would be covered in the case someone questioned your covered button.

[HoldsIt]

See the GCC is the problem. I buy them wholesale, direct from the manufacturer, out of the country... I asked when I first started doing business with them and they promised me they would have their lab forward the results to me. Well, after several rounds of asking I still have nothing so I'm pretty sure they are blowing smoke up my skirt. I was born at night... but not last night! I am contemplating having them tested just to cover myself.

The one thing I am finding from my multiple forums is that people don't understand that they have to get a new GCC every time they purchase from their supplier. They assume that one issued two years ago is still relevant but I don't think it is. If the government does crack down on this law, there are going to be a lot of folks up the creek.