Know what is in your environment

The toy holiday sensation Zhu Zhu Pet Hamsters have been declared safe by the U.S. Consumer Product Safety Commission (CPSC).  Last week, a consumer product testing company in California, Good Guide, had suggested that one specific pet hamster, Mr. Squiggles, contained elevated levels of antimony.

Antimony is regulated under the Consumer Product Safety Improvement Act (CPSIA) along with arsenic, barium, cadmium, chromium, lead, mercury and selenium for soluble “leachable” content limits.  The CSPIA also regulates lead for total content, as well as, various other toy safety standards.

Good Guide uses an X-Ray Fluorescence (XRF) Analyzer from Niton to detect a variety of heavy metals.  XRF Analyzers are great for determining the total content limits; however, XRF cannot accurately determine soluble level limits.  Soluble testing required under the CPSIA is set under testing method ASTM F963, this testing method is essentially a weak acid test that digests the material and mimics ingestion.

The CPSC did this form of testing to determine the levels of antimony and other metals in the Zhu Zhu Pet Hamsters that it tested.  It found all soluble content levels and total content level for lead were below standard limits.

This is not to say that this product doesn’t contain antimony, but there is a difference in the two limit standards (soluble content and total content). 

Let me take you a bit deeper into this world of children’s product testing.

First, the CPSIA basically requires that any children’s product (designed and marketed to children 12 and under) needs to meet certain requirements for safety.  If the product is manufactured overseas, then the importer or ultimately the retailer is required to ensure that all products do not contain specific quantities of certain metals (mentioned above) in addition to other safety standards (example: small parts, painted surfaces, phthalates, etc).

The current regulation says that (a portion of the CPSIA is under a “Stay” and this stay comes to an end on 2/10/10, meaning other regulations with go into effect) painted surfaces and children’s jewelry (metal) must be tested by an accredited 3rd party laboratory that uses specific, destructive testing methods to determine total content for lead and soluble content levels for all metals are in compliance with the regulation.  This test essentially will provide information to create a General Certificate of Conformity (GCC), which is required under the law for all CPSIA regulated products beginning 2/10/10.

Currently, all other children’s products still need to conform to the regulations, meaning that these products (plastic toys for example) do not contain more than 300 Parts Per Million (PPM) of lead, as well as the soluble limit standards for all metals.  However, no specific testing method for determining the levels of these metals in total or soluble content is given by the CPSC and no GCC is required.  

All of this will change on 2/10/10 when all children’s products will need to be tested by the approved 3rd party laboratory’s that use specific, expensive, destructive, older but well established methods to test for these heavy metals.

X-Ray Fluorescence Technology is being looked at by the CPSC as a potential means of providing compliance testing, but currently, XRF is only a suggested tool to screen for these heavy metals.

If XRF is capable of identifying if these elements are present or not present (which it is, there is only a question of quantification with XRF), XRF can be a tool in the system of consumer product safety that can help businesses, consumers and impact the CPSIA. 

XRF can help businesses by non-destructively, accurately and inexpensively complying with regulations.  This will help businesses reduce testing costs dramatically, ensure the safety of their products, get products to market faster and ultimately create jobs.  More testing, screening of products helps consumers ensure that what their children are playing with, what they are eating off of are safe from potentially harmful toxics such as lead and antimony.

How is this possible? 

Logically, if XRF can identify these elements simply as either present or not present in consumer products, we have a means of screening.  If these regulated elements are not found, why would you require a company to pay for much more expensive, destructive testing? 

If a regulated element such as antimony was found in the Zhu Zhu Pet Hamster using XRF as a first means of testing (screening), than further testing for that element should be done, but just that element.  We are not eliminating the testing laboratory, but asking for a more specific test, reducing business expenses.

In testing by Good Guide, their testing method used an XRF Analyzer, their results showed that lead, cadmium, arsenic, mercury, selenium, chromium and barium were not present, all elements part of the regulation. 

When this story first broke a few days ago, the CPSC quickly jumped in to test this product.  Using the testing methods within the CPSIA, the CPSC found that the soluble level of antimony was below the regulation standard.

Basically the CPSC confirmed the results of Good Guide; there was just a slight misinterpretation with Good Guide’s results.

Once again, this does not mean that antimony is not present, but it was determined to have passes all safety standard tests.

I believe that this is a teachable experience and that X-Ray Fluorescence (XRF) Analyzers have the ability to help businesses comply with regulation and reduce business expenses and ultimately create jobs, simply by helping people and businesses know what is in their environment.