reasonable testing...I'm so confused!

[Former_Member]

I'm confused about the "reasonable testing" until August. Unless I'm mistaken, there are no real guidelines as to what constitutes reasonable testing. So, as long as your products are not in fact over the lead limit, how could you get in any legal trouble before August? How can you comply if you aren't told how to comply?

I'm not understanding how anyone here could be fined/prosecuted before August (and 3rd party testing is required). Please help me understand if I'm not looking at this correctly. I don't want my head to explode...I really don't.

[LaurieRyan]

who isn't sugar

[Former_Member]

LOL....I thought maybe I was just losing it

[LaurieRyan]

No the law is so badly written that no can figure out what is allowed and what isn't allowed

[asherjasper]

Glad I'm not the only one!

[Former_Member]

Technically, 3rd party testing isn't mandated until August. It's just illegal to sell anything that isn't compliant. So, from your existing stock, how do you even know? Well, you have to test... The good news is, what they term "due diligence" allows XRF testing which is fast and relative inexpensive (unlike certified labs testing that's required in starting in August). One of the large clothing companies I've been testing for lead tests every different STYLE only once, but tests every fabric/button/snap, etc on it. Hope this answer helps somewhat.
Vince Merrill PhD
LeadFreeOC.com

[asherjasper]

Thanks, Vince, for the clarification :) So, basically, if I get a certificate from my wool supplier and do nothing to that wool except felt it, I'm in the clear until August?

[Dannielle]

SugarAndSpice says:
I'm confused about the "reasonable testing" until August. Unless I'm mistaken, there are no real guidelines as to what constitutes reasonable testing. So, as long as your products are not in fact over the lead limit, how could you get in any legal trouble before August? How can you comply if you aren't told how to comply?

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I think that is why the CPSC seems to think they have all the time in the world to address this issue.

I would think the same standards that apply to thrift and consignment shops apply to us as of Feb 10th. The whole "level of confidence" thing.

[Dannielle]

It's the Aug 14 third party testing regs I can't wrap my brain around. :(

[Former_Member]

Call me a rebel, but if I got hauled into court before August, I would argue that it isn't even necessary to XRF test certain things. Metal stuff? Sure. Snaps and plastic buttons? Yeah, I'd want to XR test that stuff if the manufacturer couldn't provide any assurange that it was lead-free. But acrylic craft paints that are labelled AP non-toxic? Untreated domestically grown poplar? It's like getting an MRI of the brain for a sprained ankle.

[Former_Member]

As long as the wool is untreated and unadulterated (no pigment, dyes, or coatings) I don't think you'll need a certificate even from the supplier. You might from the felt though (not sure if it's natural or synthetic). If they are dyed though, then it falls under CPSIA again...

[Former_Member]

I think I am going to go with my idea of the term "Reasonable Testing" until August 14.

Hopefully something will be done about this law before August 14, 2009.

O'heck, the date is March 23, 2009 for jewelry... Ok, I hope they fix this law before the middle of March...

:0(