CPSIA Update

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It's Christmas Eve sonot mkuch time to for a long discussion but these two links seem like a little light at the end of the tunnel, at least a hint of a merry Christmas.
Children's Products Containing Lead: Proposed Determinations Regarding Lead Content Limits on Certain Materials or Products; Notice of Proposed Rulemaking, December 24, 2008 (http://www.cpsc.gov/library/foia/foia09/brief/leadlimits.pdf)
Children's Products Containing Lead: Notice of Proposed Procedures and Requirements for a Commission Determination or Exclusion, December 24, 2008 (http://www.cpsc.gov/library/foia/foia09/brief/leadprocedures.pdf)
MERRY CHRISTMAS TO ALL AND TO ALL A GOOD NIGHT.
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wrote:

Good news!
http://abcnews.go.com/US/wireStory?ide22449
"Staff toxicologists at the product safety commission told agency commissioners in the memo that some unfinished natural materials should be considered lead free. The materials include wood and fibers such as cotton, silk, wool, hemp, flax and linen."
It's only unfinished wood, and it's not set in stone yet, but it's a start.
-Kevin
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Just saw a fox new article on the clothing side of the CPSIA and was greatly discouraged. Seems like they think that it is a good idea since everyone throws away old clothing at the end of each season, and what if a few small compinies go out of business, who cares.
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sweet sawdust wrote:

Apparently they aren't talking to the right people. How many people here throw out clothing at the end of the season? Mine goes to the shop rag pile after maybe three or four seasons and then get tossed when they are used up.
Who was saying they didn't care if a few small companies went out of business? Was it "man on the street" types of interviews, the commentators, or CPSA people?
--
If you're going to be dumb, you better be tough

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The Fox News Pro Expert. Probably from New York City, making 200grand + a year and doesn't associate with real people.
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Curran Copeland wrote:

You ain't getting rich on 200 grand/year in NY city!
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greatly
small
Is this thread arising from the ban on lead and phthalates in toys and other items? Axel
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Axel Grease wrote:

I think so.
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-MIKE-

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YES
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everyone
Thanks. A coupld of people in this group seem upset by the ban. I would ask - "How does this affect woodworkers?" What products that we use contain lead or phthalates? So far as I know, lead paint, adhesives, and solvents have not been produced in America since the '60s. It should not be a big problem to avoid.
Phthalates? For now, California has banned them in children's toys. The Feds have restricted three types of phthalates permanently, and put interim restrictions on three others.
As I understand them, esters of phthalic acid are plasticizers commonly used to soften PVC (for flexibility). How common are the restricted ones in paint, sealers, and woodworking adhesives? How many woodworking tools will be affected by a ban?
Phthalates are not natually occuring chemicals, so there seems little to worry about from phthalates leaching from wood. Fishermen who like plastic jelly worms may be upset and certain "adult" toys may also be effected, but those are OT here.
Axel
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The problem is primarily for anyone making items for children (12 and under). As the law now stands all items made for children must be tested for lead and Phthalates regardless of what they are made of. This includes wood, cotton, and other natural materials with no exceptions. They are looking at exempting items made of some natural untreated materials, but that has not gone through yet. Any natural material that is treated with pigment must be tested. Just because paint is made in the U.S. does not exempt it once it is applied to wood. This is not just the big companies but all items, including that baby rattle that Grandpa makes for Jr. or the baby blanket for little Tess from Grandma. The test can cost up to $50,000 for clothing and up to $4000 for wooden items. Each item must be tested not just the materials themselves. Fines for noncompliance are in the $100,000 range per incident and all tests must be done yearly or more often. This would also include existing items such as those found at yard sales and thrift shops. The only tools affected would be those for children as far as I can tell, so if you only make items for adults you would not be affected. For more information go to the links below.
http://www.cpsc.gov/about/cpsia/cpsia.html http://www.handmadetoyalliance.org /
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sweet sawdust wrote:

... snip

One thought that comes to mind: If the cpsia is hell-bent on implementing regulations that implement this brain-dead feel-good legislation (sorry, I'll refrain), the testing requirement makes sense for imported items since it is apparent that no control can be exerted over foreign suppliers. However, for domestically produced items, it would seem that if the manufacturer or fabricator can produce documentation for all components going into the construction of the toy that shows none of the banned items are contained in those components, then compliance could be shown. While it would require additional book-keeping, it would not be as costly because the actual component testing has already been performed by the component manufacturers. This also protects the fabricator against any changes in formulation that may occur in the future since the documentation should be kept current by the chemical manufacturers. For example, if you are making and finishing a wooden top, you would have a compliance list of:
1) Wood -- natural ingredient, perhaps the MSDS for the wood 2) Shellac -- MSDS or other ingredients documenation from the shellac supplier 3) Wax -- MSDS or other ingredients documentation from supplier
This would at least be something that would not force people out of business.
--
If you're going to be dumb, you better be tough

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They are taking comments for which types of products to allow component testing, but as it stands now very specifically component testing is not acceptable, you have to test each type of final product. MSDS usually have disclaimers on them, like this one from General Finishes:
"General Finishes believes that the information contained in this MSDS is correct as of this date. However, because the material may be used under conditions over which General Finishes has no control or in ways we cannot anticipate, we give no warranty, expressed or implied, as to the accuracy of the information. General Finishes assumes no responsibility for any damage to person, property or user of this material or to insure that it is properly and safely used."
If the manufacturer won't stand behind the information in the MSDS I don't see how you can use that MSDS as a basis for proof that the product is safe. And manufacturers aren't going to take that liability out of the goodness of their hearts.
-Kevin
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That's all just plain NUTS. Wouldn't voluntary self-compliance have been sufficient, as for the film industry's G, PG, R ratings?
wrote:

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MikeWhy wrote:

Well, now, there's the problem. Voluntary self-compliance didn't _work_.
But as enacted the legislation is either an overreaction or a screw up.

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Hmmm. I don't mean about the foreign purveyors of salmonella and lead painted toys. I mean more like a UL label that indicates privately tested compliance with industry established standards, coupled with an awareness campaign. We're obviously paying too much in taxes to have those dickheads think this is a good use of my money. Why should this require force of law? Why should even a single dollar of public money come from unrelated businesses to govern how a child's toy is made?
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MikeWhy wrote:

The testing required by the law is "private", there is no government testing agency established and no requirement that the government perform the tests. Hell, UL may end up the outfit doing it.

I'm sorry, but I'm not clear on what you're on about with "even a single dollar of public money".
What public money do you believe is being spent here?
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Careful, MikeWhy... Clarke is trying to set a trap... just so he can win at 'something!'
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Careful, MikeWhy... Clarke is trying to set a trap... just so he can win at 'something!'
------ Oooh! What's the prize? ;)
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MikeWhy wrote:

<plonk>
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--John
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