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analytical challenges for determining product compliance with cpsia legislation

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analytical challenges for determining product compliance with cpsia legislation

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    1. Analytical Challenges for Determining Product Compliance with CPSIA Legislation

    4. The U.S. CPSIA (Consumer Product Safety Improvement Act) now has mandatory acceptable levels for total lead, phthalates and ASTM F963 soluble metals in children’s products. The CPSC defines a “children’s product” as a consumer product designed or intended primarily for children 12 years of age or younger. ASTM F963 includes the requirements and test methods for toys intended for use by children under the age of 14.

    5. The number of metals is greater in the E.U., and Cadmium will probably be added to the U.S. list this year. For example, Wal-Mart already has a maximum level of 75 ppm Cd, and Walt Disney bans it entirely, but has a “Not Detected” limit of 40 ppm.

    6. In 2009, Last year the CPSC suspended certification of the analysis of these materials for one year. However, the requirements and conformance were never suspended, so certification was, in effect voluntary.

    7. Continuing to use them as an example, Wal-Mart and Disney believed that it was in their best marketing interests to continue certification. They, and other companies, list this conformance on their packaging, in the attempt to boost consumer confidence with their products. However, last month, certification of products became mandatory again.

    8. The limits on the amount of lead in children’s products are phased in over the course of three years. Children’s products that contained more lead than 600 ppm were banned in the U.S. after February 10, 2009, “Paint, coatings or electroplating may not be considered a barrier that would make the lead content of a product inaccessible to a child.” On August 14, 2009, this limit was lowered to 300 ppm of lead.

    9. The limit goes down to 100 ppm on August 14, 2011, unless the Commission determines that it is not technologically feasible to have this lower limit.

    10. Paint: On August 14, 2009, the Act provides that paint and similar surface-coating materials for consumer were to be reduced from 600 ppm to 90 ppm

    11. As a replacement for lead, many Chinese manufacturers substituted Cadmium (and sometimes Antimony or Barium). Cadmium is a known carcinogen. Accordingly, this has now caused major concerns and is under discussion. Cadmium is not mentioned specifically in CPSIA. Accordingly, many labs incorporate the ASTM standard, which includes a limit of 75 ppm soluble cadmium in surface-coating materials on toys.

    12. ASTM F963 safety standard for children's toys currently includes:     Lead in paint: 300 ppm     Soluble lead (Pb): 90 ppm     Soluble antimony (Sb): 60 ppm     Soluble arsenic (As): 25 ppm     Soluble barium (Ba): 1,000 ppm     Soluble cadmium (Cd): 75 ppm     Soluble chromium (Cr): 60 ppm     Soluble mercury (Hg): 60 ppm     Soluble selenium (Se): 500 ppm

    13. Sampling is always an issue: Are you taking an accurate representative sample? Are you getting all of the pieces? Then, sample preparation: Is it a dissolution, or an adequate extraction? Which acid choice? The method, or something better (A.R.)? The customer may prefer a dissolution method more powerful than that of the published method Is the HotBlock enough, or do you need Microwave Digestion? Finally, analysis: Do you filter the residue, or try to sample it without clogging your autosampler? Is the result repeatable?

    14. If the item is coated with paint or a similar surface coating, the coating is removed and analyzed separately from the base metal for lead content.

    15. Typical sample types processed by VHG Labs include children’s jewelry, toys, and other children’s products.

    16. If the item is coated with paint or a similar surface coating, the coating is removed and analyzed separately from the base metal for lead content. This often involves disassembly of the product.

    17. Samples are ground or chopped up “into as many pieces as possible.” This can include rasping (filing):

    18. Alternately, samples are often simply chopped up into homogeneous subcomponents:

    19. Here is a typical sample before-and-after:

    20. Samples are then weighed:

    21. Appropriate acid(s) is (are) added and put into a Hot Block or Microwave for digestion*:

    22. And the resulting digest may or may not be require filtration:

    23. Next, the samples are analyzed via AA or ICP. We use NIST controls for these analyses:

    24. Finally, the results are reported:

    25. Pink, green and blue hoop, setting and flower setting earring set :

    26. Pink, green and blue hoop, setting and flower setting earring set :

    27. VHG Labs existing Analytical Services lab was fortunately already prepared to handle the analysis vis-à-vis instrumentation. However, we did not have adequate personnel to handle the sampling. In addition, we needed a better method of producing reports on a large scale. We were able to successfully implement a growth strategy that embraced end-to end high-volume sample throughput. During this process, we overcame the challenges of product sampling, sample preparation, and analysis. In the end, it made our entire Analytical Services division larger and more streamlined

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