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
Children's Products Containing Lead: Notice of Proposed Procedures and
Requirements for a Commission Determination or Exclusion, December 24, 2008
MERRY CHRISTMAS TO ALL AND TO ALL A GOOD NIGHT.
"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
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.
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
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
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.
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.
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.
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
3) Wax -- MSDS or other ingredients documentation from supplier
This would at least be something that would not force people out of
If you're going to be dumb, you better be tough
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 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.
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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