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Toys and Other Children’s Products. January 22, 2010.

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Presentation Transcript
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Toys and Other Children’s Products

January 22, 2010

This presentation is based on the best available information as of this webinar.  As interpretations and clarifications of the CPSIA requirements continue to evolve, the information included in this presentation may change.  STR continues to monitor the CPSIA closely and to provide recommendations and consultation to our valued clients based on the best available information.

Raising the world’s expectation of product quality, safety and supply chain responsibility

specifically
Consumer Product Safety Act: Notice of Commission Action on the Stay of Enforcement of Testing and Certification Requirements

Interim Enforcement Policy on Component Testing and Certification of Children’s Products and Other Consumer Products to the August 14, 2009 Lead Limits

Stay Informed!!

Sign up for CPSIA updates at www.cpsc.gov

Read STR News Alerts

Specifically…
slide3
Original CPSIA Schedule for Mandatory Third Party Testing & Certification for Certain Children’s Products
slide4
Does not

Postpone compliance with the 2/10/09 requirements

Affect the applicability of lead and phthalate ban to existing inventory

Stop the testing and certification requirements from going into effect but merely postpones them

Postpone the testing and certification requirements which have already been implemented

Does

Provide opportunity for CPSC to establish rules needed for implementation of the lead provisions

Provide CPSC time to rule on exemptions and exclusions from lead, and develop an approach to component parts testing

Provide CPSC an opportunity to provide detailed guidance on how to comply with requirements

January 30, 2009: CPSC Grants One Year Stay of Testing & Certification Requirements for Certain Products

Stay scheduled to be lifted 2/10/10

slide5
Stay not extended for

Youth bicycle helmets

Bunk beds

Infant rattles

Dive sticks

Stay extended for all other children’s products, and

GCC’s are Not Required until third party testing becomes mandatory

December 18, 2009:CPSC Extends the Stay of Enforcement on Testing & Certification Requirements for Many Children’s Products
mandatory third party testing certification of children s products
Mandatory Third Party Testing & Certification of Children’s Products

Currently Required

Lead in Paint

Cribs

Pacifiers

Small Parts

Lead in Children’s Metal Jewelry

mandatory third party testing certification of children s products7
Mandatory Third Party Testing & Certification of Children’s Products

Required once Stay of Certification and Testing is lifted (for products manufactured after 2/10/10)

Youth Bicycle Helmets

Bunk Beds

Rattles

Dive Sticks

mandatory third party testing certification of children s products8
Mandatory Third Party Testing & Certification of Children’s Products

Stay of Certification and Testing extended

Youth Bicycles (until 5/17/10)

Lead Content (until 2/10/11)

mandatory third party testing certification of children s products9
Mandatory Third Party Testing & Certification of Children’s Products

Required 90 days after CPSC publishes laboratory accreditation requirements

Youth All Terrain Vehicles

Baby Walkers and Bouncers

Caps and Toy Guns

Youth Carpets and Rugs

Clacker Balls

Children’s Sleepwear, and…

mandatory third party testing certification of children s products10
Mandatory Third Party Testing & Certification of Children’s Products

Durable Nursery Products

Electrically Operated Toys

Youth Mattresses

Phthalates

Small Balls and Marbles

Youth Swimming Pool Slides

Toys (ASTM F963)

Flammability of Vinyl Plastic Film (Youth Apparel)

Flammability of Youth Wearing Apparel

mandatory gcc s for non children s products
Mandatory GCC’s for Non-Children’s Products

Required once Stay of Certification and Testing is lifted (for products manufactured after 2/10/10):

Architectural glazing materials, ATVs, Adult bunk beds, Candles with metal wicks, CB antennas, Contact adhesives, Cigarette lighters, Multi-purposes lighters, Matchbooks, Garage door openers, Portable gas containers, Lawn mowers, Mattresses, Unstable refuse bins, Refrigerator door latches, Swimming pool slides, Products subject to Poison Prevention Packaging Act, Paint and household furniture subject to lead paint regulation (16 CFR 1303)

mandatory gcc s for non children s products12
Mandatory GCC’s for Non-Children’s Products

Stay of Enforcement extended for:

Adult bicycles

Carpets and rugs

Flammability of vinyl plastic film (adult apparel)

Flammability of adult wearing apparel

GCC’s not yet required for above

GCC’s currently required for pool drain covers

GCC’s based on “reasonable test program”

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Interim Enforcement Policy on Component Testing and Certification of Children’s Products and Other Consumer Products to the August 14, 2009 Lead LimitsDecember 18, 2009 Press ReleaseDecember 28, 2009 Federal Register

component testing
Applies to Lead in Paint and Lead Content (lead in substrates)

Allows manufacturers and importers to certify products to the lead requirements in one of 2 ways:

Have test reports from CPSC-recognized 3rd party lab showing that each paint on the product complies, or

Have certificates from paint suppliers declaring that all their paint on the product complies based on testing by CPSC-recognized 3rd party lab

Remember that Lead Content does not yet require 3rd party testing

Component Testing
wet paint testing
Paint certificate should list each paint used, by color, location or other means

For each paint, certificate should identify the corresponding test report

Certifying person should be able to trace each batch of paint to the paint manufacturer

Product manufacturer should ensure that paints are not contaminated with lead during application to the product

Wet paint tested should be “representative” of paint used on final product

If drying agent is mixed with paint on final product, wet paint test sample should include the drying agent

Wet Paint Testing
raw material substrate testing
Component certificate should identify each component tested by part number or other specification, as well as component manufacturer or supplier

Plastic resins can be tested in raw state

Manufacturer must take care that manufacturing process does not add lead

Composite testing for lead content is acceptable!

Combine like materials (plastics, metals)

Raw Material Substrate Testing
enforcement policy
Reliance on certificates or raw material test reports must be reasonable

Cannot be relied upon to certify product if one believes results are false or misleading

Manufacturer or importer who certifies product compliance based on certificates or raw material test reports will not be subject to civil or criminal penalties if violation is found

Issuer of the false or misleading certificates is subject to penalties

Enforcement Policy
str recommedation on cpsc s interim policy
STR does not recommend wet paint or raw material testing alone to certify product compliance

Lead contamination can occur during manufacturing:

Cleaning solvents used on spray masks or screens (some use leaded gasoline)

Spray mask or spray gun containing residue from previous (leaded) paint, or molding machines containing residue from previous material with lead

Rust (on mixing tools, stirrers, brushes, paint cans or other paint storage containers)

Leaded solder used on paint storage containers or plastic grinding machines

Additives to paint such as thinners, or mold release agents used in plastic molding

STR will test wet paint or raw materials upon client request and based on CPSC’s Interim Policy – after discussion with client on potential issues

STR Recommedation on CPSC’s Interim Policy
str recommendation on other component testing
STR overall supports component testing

Eliminate redundant testing

Reduce required number of samples

Component testing is suitable only for certain tests

Chemical, not P&M or Flame

STR Recommendation on Other Component Testing
acceptable component testing
Lead in paint can be done on samples that are fully painted with production paint (doll head painted with eye paint)

Must use same application process and equipment as final product

Finished components can be submitted

Doll eyes only, not entire doll – for lead in paint, lead content, phthalates

If identical components are used in more than one style, testing can be done once and results transferred

Must be from same lot, produced at same factory and within same time period

All styles must be identified at time of submittal

In all cases, traceability must be evident

Acceptable Component Testing
other new cpsia notices
Two day public workshop on 1/11 and 1/12 on Public Consumer Product Safety Incident Database

Registration card requirement for durable infant products

6 products added to list in CPSIA: children’s folding chairs, changing tables, infant bouncers, infant bathtubs, portable toddler bed rails, infant slings

Appointment of Chronic Health Advisory Panel to evaluate phthalates and phthalate alternatives

Second set of 3 phthalates under interim ban (DINP, DIDP, DnOP)

CHAP results in 18 months

Exemption from Lead Limits for Certain Electronic Devices (16 CFR 1500.88)

If not technologically feasible to eliminate lead

If lead is required for function

Other New CPSIA Notices
keeping informed
CPSC website (www.cpsc.gov)

Sign up for CPSC email alerts on CPSIA

STR website - CPSIA FAQ (www.STRQuality.com) 

STR Monitor Newsletter and News Alerts

Keeping Informed