Applied Technical Services, Inc recently had a representative attend the CPSC Workshop, which was held in Bethesda, Maryland on December 10th & 11th, 2009. The workshop was held to discuss testing, certification, and labeling of consumer products, which relates to Section 14 of the Consumer Product Safety Improvement Act. As a testing lab that looks to provide CPSC testing to those affected by legislation, we also want to keep you informed of the items discussed at this most recent Workshop.
Reasonable Testing Program
The CPSC did state that as the manufacturer/distributor/importer, you should have a “reasonable testing program” in place. So the question you may be asking yourself is: what defines this? As the manufacture/distributor/importer, this is up to you and what you can justify as a “reasonable testing program”. If the CPSC pays you a visit, you need to be able to provide justification for your compliance program. You need to fully understand your processes, in order to determine what a “reasonable testing program” is for your final product. What may be a “reasonable testing program” for a locally produced hand-made item may be different for items produced by foreign manufacturing. Regardless of your size, the CPSC did state that as part of the testing program, 3rd party testing of the finish goods by an accredited lab must be part of this.
The reasonable testing program must be inclusive of 5 items:
Proper Sampling for Testing
This is another part of the program that is particularly important. What does the CPSC mean by proper sampling? Random sampling is what they expect with your process. The number of samples tested is important. Sampling from batches randomly is the proper way to test items. Depending upon your process, it may not be sufficient to conduct one lead test on your item. Due to this, it may be necessary to randomize your samples for each batch or lot. Again, this goes back to knowing your process and understanding where a potentially hazardous element or contamination could enter your process.
3rd Party Testing
Even if you are using a screening technique such as XRF, the CPSC states that you still have to do 3rd Party Testing to verify compliance. Conducting 3rd party testing of the finished goods is not an option, but a requirement of the CPSC. After conducting these tests, documentation is important and maintaining adequate records is critical.
Verification of 3rd Part Test Results:
The important piece here is to make sure the lab you are working with is accredited. If it’s not, then your tests results would be invalid. So, with this in mind, make sure you do your homework up front and confirm the labs accreditation. Annual re-certification by an approved accrediting body is required for labs in which they have to prove proficiency.
Cadmium is also regulated under CONEG and toxic in packaging regulations. CONEG states that total concentration of the heavy metals lead, cadmium, mercury, and hexavalent chromium should not exceed 100 ppm. Additional regulations may apply and the requirements can vary by state, so be sure to check with current legislation.