Know what is in your environment

July 27, 2010

Essco Safety Check is offering Free XRF Testing for heavy metals at Autism Day of Washington

Essco Safety Check will be providing FREE X-Ray Fluorescence (XRF) Testing for heavy metals; lead, cadmium, arsenic, mercury, antimony and more at Autism Day of Washington.  Autism Day of Washington is an annual event held out at the Jubilee Farm in Carnation, WA.  In its 10th year, Autism Day of Washington will be on Saturday, August 7th 2010 from 11AM to 3PM.

Autism Day Washington 2009 booth

Autism Day is a free, fun-filled event designed for families touched by autism – a chance to relax in a beautiful setting surrounded by people who understand. Various individuals, companies, service providers and organizations wishing to reach out to the autism community provide free activities with our children in mind. The event is spread out with booths, an hour long slip-n-slide event, adaptive cycles and various food vendors.

Essco Safety Check is participating for the third year in a row and will be offering FREE XRF testing for heavy metals.

Bring your toys, ceramics, jewelry, favorite coffee cup, baby products, paint chip samples, yellow bumbo seats or anything you would like to have tested for heavy metals.   All testing is non-destructive and takes a few seconds to perform.

Please visit our booth on Saturday, August 7th, 2010 from 11:00 AM to 3:00PM for FREE Consumer Product Testing, to ask us any questions about heavy metals in your environment, to pickup special offers or simply learn more about Essco Safety Check.

Autism Day Washington Hayrides 2009

Enjoy the hayrides, farm animals, beautiful flowers, open spaces, camaraderie and free consumer product testing. See you down on the farm!

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July 5, 2010

Free XRF testing provided by Essco Safety Check Saturday, July 10th, 2010

Essco Safety Check will be participating in Redmond Derby Days and Impact Eco-Fair on July 10th, 2010 from 10:00 AM to 6:00 PM by providing FREE X-Ray Fluorescence (XRF) testing for heavy metals. The Eco-Fair will be located at Redmond City Hall Campus 8703 160th Avenue NE Redmond, WA 98052.

The Eco-Fair will feature:

  • Free Consumer Product Testing by Essco Safety Check
  • A Green Car Show
  • Solar Powered Sage
  • A green business showcase, discount and resources for going green
  • Fun items for kids
  • A root beer garden and more!
  • Stay late for a fireworks spectacle at Redmond City Hall Campus at 10:00 PM

    If you would like to have any consumer products tested for heavy metals (lead, cadmium, arsenic, mercury, antimony or other heavy metals) please visit our booth between 10:00 AM and 6:00 PM on Saturday, July 10th, 2010. Bring you toys, ceramics, jewelry, paint chip samples, yellow bumbo seats or anything you would like tested, we will be on hand to provide free testing and answer any questions you may have.

    All testing is non-destructive and takes a few seconds to perform. For more information about Redmond Derby Days and Impact Eco-Fair, please visit or for more information at Essco Safety Check please visit.

    We look forward to seeing you this Saturday.

    If you are unable to stop by this Saturday we will be participating in another community event in August at WA Autism Day at the Jubilee Farm in Carnation on August 7th from 11:00 AM to 3:00 PM and providing free testing for all participants.

    Know what is in your environment!

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    April 6, 2010

    Do you know what is in your kitchen?

    Filed under: Health, News, viewpoint — Tags: , , , , , , , — Seth Goldberg @ 11:05 am

    Let me start by saying that I am not trying to scare anyone, I just want to provide information about what we find during environmental inspections that my company performs.  It is ultimately up to you to understand your environment and make educated decisions as to what you and your children are exposed to. 

    In the past few years, we have heard all too frequently about lead and now cadmium found in children’s toys and children’s jewelry.  Children’s products are regulated by the Consumer Product Safety Improvement Act (CPSIA) which limits the amount of certain heavy metals in consumer products designed for children 12 years of age and younger.  In my experience, toys typically have lower amounts and frequency of possessing lead, but do you know what is in your kitchen?

    Recently I was out performing an in-home inspection specifically looking for lead for a family that had three young children, all with lead found in their blood.   My company (Essco Safety Check) specializes in using X-Ray Fluorescence (XRF) analyzers, which is a non-destructive, accurate, efficient testing source to determine if specific elements such as lead, cadmium, arsenic or mercury are present in virtually anything (toys, ceramics, jewelry, soil, structures, etc).   In this particular home, there was actually very little lead found in the children’s products or in the structure of the home. 

    When we provide testing, we typically want to test the items that people, specifically children are routinely exposed to.  I want to test the things that children put in their mouths, the items that they have regular contact with and could potentially be a source of harm.  I never hope to find lead or other harmful toxicants, but it is typically found in the average home in a variety of different products, substrates and locations.  I’m not here to say that these toxicants are going to harm or have harmed anyone; however, if present they maybe a potential source of harm.

    After testing most of the children’s products that are used regularly and specifically placed in their children’s mouth, I proceeded to the kitchen to further analyze items that could potentially be the source of lead in the children.  Now in my experience, the kitchen typically possesses the most amounts of potentially harmful metals, specifically in ceramics.  This home did have some heavy metals in their ceramics, and in one case, a ceramic piece of cookware was found with lead over 5500 PPM. 

    With a ceramic, the most important thing to look at (besides the elemental makeup) is the condition of the glaze.  If the condition of the glaze of a ceramic is not compromised, you should not have to worry about the makeup of that ceramic.  However, if the ceramic in question has a compromised glaze (there is a crack, chip or blemish) you should take note of what that ceramic is made of.  Unfortunately the only way to know what the ceramic is made of is to have it tested.

    The ceramic found with lead did have a compromised glaze, and the owner decided not to use this item any more (it was given to me to use as an educational display piece).  But in this kitchen I found something that I’ve never seen before.   I found lead in a plastic ladle! 

    Black plastic ladle found with lead (750 PPM)

    Black plastic ladle found with lead (750 PPM)

    I’ve seen lead all over the place in the home and specifically the kitchen, but not in a serving utensil.  I’ve found lead and other toxicants (cadmium and arsenic) in ceramics, pots and pans and even a cutting board.  I’ve had conversations with toxicologists and elemental specialists from the FDA.  Do you know that your coffee cup is regulated by the FDA (inside of the cup) and CPSC (outside of the cup)?

    The amount of lead found in the ladle was approximately 750 PPM.  This level is over twice the total content level for a children’s product (CPSIA), but this product is not regulated as a child’s product.  I’m not suggesting that this ladle is even the source of this specific case of lead found in children’s blood, but lead was found in a product that is exposed to a variety of different heat conditions , as well as, the potential for acids (like tomato soup) and children are exposed to  and this type of product.

    As I said at the beginning, I am not here to scare anyone; I am here to provide insight and knowledge.  I’m not saying that the ladle or cookware was the cause of lead in the children from this home, but lead was found in the kitchen and in consumer products that children are exposed to on a regular basis.

    Do you know what is in your kitchen?

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    March 5, 2010

    Free Toy and Consumer Product Testing At the Healthy Kids & Green Parenting Fair

    Children photo kids green parenting fair

    Healthy Kids & Green Parenting Fair

    Saturday, March 20th, 2010 10am to 3pm

    Mark your calendars and tell your friends about the upcoming Healthy Kids and Green Parenting Fair, sponsored by the Tacoma-Pierce County Health DepartmentEssco Safety Check is participating in the Healthy Kids & Green Parenting Fair by providing FREE toy and consumer product testing to the public. 

    This year’s fair will be held on Saturday, March 20th, 2010. It will be in the auditorium at the South Park Community Center (4851 South Tacoma Way) and will be open to the public from 10 a.m. to 3 p.m. Admission is free.

    Bring your children’s toys, family heirlooms, jewelry, dishes, coffee cups, plastic bottles or anything that you would want non-destructively tested for harmful heavy metals.  We utilize laboratory-grade, handheld, X-ray Fluorescence (XRF) analyzers to detect the presence of a variety of potentially harmful elements such as lead, cadmium, arsenic, mercury, chlorine, and other elements.

    The fair is a place to learn about protecting your child from toxins in the environment, and to find resources to help you make healthier, greener choices, like safer toys and personal care products, natural yard care, organic foods, cloth diapers, breastfeeding, and babywearing. We will offering free lead testing of toys and other consumer products, but there will be free blood lead testing for children and pregnant or nursing moms. There will be a babywearing fashion show at 11 a.m. and drawings all day for really fantastic door prizes including an organic ERGObaby Carrier, Sleepy Wrap, cloth diapers, Hotsling, BabyLegs, organic cotton baby clothes, and a nursing pillow/cover. Free eco-friendly art supplies for the first 50 kids attending!

    For more information visit http://www.essco-safetycheck.com/PR/HealthyKidsGreenParentingFair3-20-10.pdf or contact Chris Matter-Rinehart at 253-798-6492 or cmatter@tpchd.org. See you there!

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    February 25, 2010

    One Small Business Rises to the Challenge; Creating Jobs, and Stimulating Small Business

    If i ran the government – Permit XRF screening with the CPSIA

    The current administration has challenged businesses across the country to help create new jobs.  Environmental Services & Solutions Corporation (Essco Safety Check), a Redmond, WA based company steps up to the government’s challenge by:

    • Proposing the creation of thousands of jobs. 
    • Helping to stimulate business; especially small businesses impacted by the Consumer Product Safety Improvement Act (CPSIA).

    The CPSIA (Consumer Product Safety Improvement Act) is a law that regulates the amount of lead and other harmful toxicants in children’s products.  There are approximately 700,000[1] manufacturers, importers, wholesalers and retailers that are impacted by this current legislation; approximately 40%[2]of these businesses have 0-4 employees working for them.

    Currently, XRF testing is not a government approved testing method.  Current approved testing methods are destructive in nature; which means the tested product must be destroyed during the testing procedure.  This method of testing is very costly and the test results could take weeks to obtain.  In addition, products can only be tested by a select group of government approved testing laboratories worldwide.

    XRF testing equipment is completely portable; it can be easily transported to the testing site.  Testing using XRF is non-destructive, low-cost, fast and an accurate way to determine if elements (including those regulated by the CPSIA) are present or not present in virtually anything.  If XRF technology becomes a government approved screening process, it is estimated that thousands of jobs could be created nationally.  These jobs include certified consumer product inspectors, support staff and office positions.

    A direct result of XRF screening is to prevent potentially harmful products from reaching the retailer’s shelves and eventually the homes of consumers. 

    By utilizing XRF analyzers to screen consumer products, businesses could save money on government mandated testing expenses and be able to get products to market faster.  For example, traditional testing is destructive in nature, very expensive and time consuming; it costs, on average, $100 per test (each product may need 5 tests) and can take weeks for results.  XRF testing costs on average $2 to $7 per test and usually provides results within 48-hours.

    Hypothesis:  If XRF Analyzers and technology are approved for screening heavy metals in children’s products and with a conservative estimate of 5 million products that need to be tested with an average of 5 tests per item, over $3.7[3] billion dollars can be saved.  However, research has suggested that there are literally tens of millions of products that are potentially impacted by the CPSIA regulation and, with that number in mind, there could be savings in the tens of billions of dollars for business all while creating thousands of jobs.

    ESSCO-Safety Check proposes that by using XRF technology:
    • Thousands of jobs can be created.
    • Businesses will be in compliance with CPSIA regulations.
    • Mandatory testing expenses are reduced for business.
    • Products get to market faster.

    It’s a win-win situation for consumers, the environment and business.
    www.essco-safetycheck.com

    [1] www.naics.com North American Industrial Classification System
    [2] www.census.gov  U.S. Census Bureau
    [3] http://handmadetoyalliance.blogspot.com/2010/02/allowing-xrf-testing-for-cpsia.html Handmade Toy Alliance Blog – Cross Post from Essco Safety Check

    February 12, 2010

    Cadmium found in jewelry and other consumer products

    Last month, an investigation by the Associated Press found alarming high amounts of cadmium in children’s jewelry.  This investigation lead to a recall of children’s jewelry and further investigation by the Associated Press has found cadmium in adult jewelry as well.

    Considering that data that we have collected for over two years assisted with the initial investigation with the AP reporter, I thought I would look further into the data about cadmium and share this information. 

    The information is only about consumer products and was collected by using X-Ray Fluorescence (XRF) analyzers to look for a variety of heavy metals by using X-Rays to determine if elements are present or not present in virtually anything.  Over 8000 test results have been compiled.

    The data present in this article is looking at a total content for cadmium found at 40 Parts Per Million (PPM) or greater.  In 2008, Washington State passed the Children’s Safety Product Act (CSPA) which regulated lead and cadmium in total content (Lead at 90 PPM and Cadmium at 40 PPM) which are stricter standards than were established by the Consumer Product Safety Improvement Act (CPSIA).  Considering that total content of cadmium is not part of the federal regulation, and my company is based in Washington State, I have decided to use that number as my standard for this data.

    My desire is not to scare anyone with this information; I am just trying to provide some awareness.  Just because we find some harmful metals in everyday items does not mean that they are going to harm you, however, they are present and that means there is a potential for harm.  With knowledge and awareness you can mitigate harm.

    XRF analyzers provide awareness, fast, efficiently, accurately, non-destructively and very economically.

    During our testing we have found cadmium and lead in a variety of different substrates including; metal jewelry (necklaces, rings, pins and pendants), glass, plastics, ceramics (cups, plates and bowls), cooking equipment, furniture, toys, handbags and even personal care items.

    In total we have found 3.64% of all items tested appear to have cadmium.

    Age of the item also appears to make some difference.  In items that were brand new, we have found 2.75% of these items to have cadmium, yet used “older” items have approximately 4.88% cadmium.

    Children’s products in general have less cadmium than the average with 2.63% found with cadmium.

    Of all substrates tested the three with the highest percentages of items found with cadmium are ceramics, metals and glass. 

    Ceramics are typical items found in the kitchen environment; coffee cups, plates, dishes, cooking equipment and the like.  Of all ceramics tested we have found cadmium in 12.03% of these items. 

    Metal substrates refer mostly to jewelry, but some metals found with cadmium include pots and pans.  Of all metals tested we have found cadmium in 9.09% of these items.  However, two points standout when the data is further evaluated concerning metal.  The levels of cadmium found in these items appear to be much greater than other substrates and when we breakdown the results by age, children’s products appear to have a slightly higher average then overall metals.  I have seen cadmium over 10% in many of these items.

    Glass is typically found in two types of products, jewelry (beads) and kitchen items.  Although we find that glass as a substrate appears to have the most overall percentages found with cadmium of any one substrate, these levels appear to be much lower than jewelry.  Overall, with glass substrates tested we have found 30.68% to contain cadmium.

    Once again, I just wish to provide awareness, my goal is not to scare you!

    Please don’t go run to your kitchen and throw away your dishes and coffee cups.  With ceramics, the most important thing is the condition of the glaze.  If the glaze appears to be in good condition with no cracks, chips, blemishes, than you really shouldn’t worry.

    This was just a snap shot of cadmium found in the typical home, with typical consumer products, using XRF analyzers.

    If you know what is in your environment, you can mitigate harm.

    January 16, 2010

    The Individual, the item and the relationship!

    Filed under: viewpoint — Tags: , , , , , — Seth Goldberg @ 12:31 pm

    Earlier this week I was interviewed by Connie Thompson of ABC KOMO News 4 (about how my small company assisted with initial data that lead to an AP investigation about cadmium in children’s jewelry) and asked a question that I’ve been thinking about ever since.  Should parents be truly concerned about heavy metals in children’s products?

    This is such a big question and every time I talk about this subject I try and emphasize a few points that I wanted to share.

    First, the information we provide is potentially “scary” and it is not my intention to scare anyone, I simply want to provide information and knowledge about your environment.   We use X-Ray Fluorescence (XRF) Analyzers to look for heavy metals in virtually anything, and my company Essco Safety Check has been providing this knowledge for over two years.

    With this knowledge you can make educated decisions as to what you and your children are exposed to. If you know what is in the consumer products you and your children use, you can mitigate harm by simply reducing exposure to that item.

    I want to also emphasize that it would be my first choice to test and work with manufacturers, testing items before the enter stores or consumers homes; however, that is not always the case and many concerned families and businesses have contact us about our testing services.

    Here are my thoughts about to try and answer the question, “what are parents and people in general suppose to do about potentially toxic metals in consumer products.”

    There are several different attributes that add to this pending “equation” to answer what is a parent suppose to do, I’ve narrowed this discussion down to three main components: The individual, the item and the relationship to that item “use”.

    All of these factors add up to a dizzying amount of questions of which are almost impossible to answer all of them.

    The Individual

    Every person is slightly different; we all have different characteristics.  We are all different heights and body masses.  Some people can run a marathon; others can sit at a computer desk for hours.  We all have different immune systems and this is really the point I want to talk about with the individual. 

    Some people never get sick and always have energy; other people always get sick and never feel like they have enough energy.  Some people are allergic to a variety of different things; other people appear not to be allergic to anything.  We all react differently to different things; Heavy metals and chemicals are a part of those things.

    It could be as simple as what genome type are you?  (Let me also add, I’m not a doctor, these are just my opinions) I remember as a child playing with mercury, and yet I appear to be fairly normal.  I suspect it is because I can process these metals and chemicals that we come in contact with.  Maybe there is a specific genome that just has this inability of processing these metals and chemicals we are routinely exposed to.

    This is also where I begin to think about autism and specifically autistic children.  In my experience of providing XRF testing services I’ve been to dozens of homes with autistic children and meet dozens and dozens of families a various community events.  All the parents of these autistic children tell me that their children have heavy metals in their blood, and coincidence or not, when I test at their homes, I find the same heavy metals in the consumer products that these children use regularly.

    This is why the individual is a very hard part of the equation.  When asked what to do with children’s products specifically (children 6 and under are at the most critical time to reduce toxic element exposure) I generally suggest to mitigate exposure to certain heavy metals as much as possible, those include; Lead, cadmium, arsenic, mercury and others depending on a variety of things including individual situations (like autistic children). 

    If you can reduce your contact with these heavy metals, you are mitigating exposure and preventing potential harm to your children, you, your pets and others.

    The Item

    Everything we use in our lives is made from a variety of different elements.  Water is a combination of hydrogen and oxygen, steel is typically a combination of iron and a variety of other metals.  All consumer products are made from the same variety of elements.  The items we all use are slightly different depending on what they are manufactured with, when they are manufactured and where they are manufactured.

    In over two years of testing I have unfortunately found harmful heavy metals in a variety of children’s products and general consumer products.  It is generally a random find and in my opinion is simply from the raw materials that are used in the production of these items.  I’m sure there are a few cases where there are intentional uses of harmful metals (for cost purposes), but for this discussion I’m talk about random finds.

    The item part of the equation is fairly simple, what is the item made with?  If it is not made with any potential toxicants, then there is really no worry regardless of the individual part.  But, if the consumer product does contain a potential toxicant, like lead or cadmium, there are definitely more questions to ask.

    What’s in the item?  How much? Is it on the surface, like paint? Or is it integrated in the coloring of the entire product?

    The relationship “use” of the item

    Here is where all of this is combined.  Once again, if you have a consumer product that doesn’t have any toxicants, besides harm of swallowing or various other safety concerns, regarding heavy metals, I’m going to tell a parent not to be concerned.  If the item in question has harmful toxicants present, then we have some concerns and questions to ask.

    How is the item used?  How often?  Is a child putting it in their mouth?  If so, I’d try and stop that immediately.

    Is the item painted?   If so, is the paint the problem? If so, what is the condition of the paint?

    What is the item made of?  If the item is made of PVC I’m going to have more concerns because of the greater potential for the harmful toxicants to leach out.  Is the item jewelry and made of metal?  There are concerns about sucking on these types of items.  Is the item of natural fibers? 

    There are just so many questions, but ultimately, how that product is used is an important question to answer if the item has a harmful toxicant.  Is this item something that just sits around and never gets interacted with? Or is it something used often?  I’m concerned about the items that have a direct use relationship with people.

    I’m not overly concerned about a picture frame on your wall, which has lead, unless that picture frame is painted and that paint is cracking and chipping.   That picture frame has very little interaction with you and your family in your environment.

    Now the things that your children play with, the things that you and your children eat off of and you drink out of I am concerned about.  These are the items that I want to understand how they are used, what they are made of, what environmental conditions are these items exposed to (different heat)?

    Do you take your children’s toys, the plastic ones (PVC) and sanitize them in the dishwasher? If so, they can be exposed to a variety of different heats, as great as 360 F.  When you go to the beach do you leave toys in the car that are exposed to direct sunlight?  Do you use something to cook with that goes from the oven to the dishwasher to the freezer?

    When you start to add up this equation, it is fairly long and very hard to answer.

    Here is my simple thought. 

    Why are children’s products and the items we cook with, eat off of and drink out of permitted to have these harmful toxicants?  I’m not suggesting that these elements don’t have certain good uses; they do, just not in these items.

    Until that day comes, it is potentially a good idea to know what is in your environment. 

    I hope that this helps in your understanding.

    Don’t live your life in fear, just be aware and mitigate harm with knowledge.

    January 11, 2010

    The US CPSC is investigating cadmium found in children’s jewelry

    What can I say? Being on the frontlines by operating a consumer product testing business, I’ve seen this trend developing.  My company, Essco Safety Check, was mentioned along with HealthyStuff.org for providing data to Justin Pritchard, the AP reporter who wrote the article “AP: Feds probe cadmium in kids’ jewelry from China” January 10th, 2010 

    All indication from our testing data suggests that cadmium appears to be increasing in all consumer products, not just children’s jewelry.  We also have seen an increase in antimony, while lead appears to be leveling in children’s products, which is regulated fairly strictly.  However, our testing has shown an increase in lead in non-children’s products.

    Apparently, the Associated Press conducted their own independent testing of children’s jewelry purchased in New York, Ohio, Texas and California.  Their testing was conducted by chemistry professor Jeff Weidenhamer of Ashland University of Ohio, who has worked with the CPSC in the past. The results found cadmium in children’s jewelry at a level of 100,000 PPM (10%) or greater in 12 percent of the 103 items tested.  This testing is what is leading the US CPSC to investigate cadmium found in children’s jewelry.

    Let me give you some back ground information for you to understand what cadmium is and how it is regulated.

    Cadmium is a metal found naturally occurring in the earth’s crust.  It does not corrode easily and has many uses, including batteries, pigments, metal castings, and plastics.  However, Cadmium is a known carcinogen, plain and simple.  It is a potentially harmful toxicant!

    Why is it increasing in our consumer products?  Fairly simply in my opinion, lead is now a fairly well regulated metal and manufacturers are substituting a metal (cadmium) that is readily available, has limited regulations and is inexpensive. 

    The Consumer Product Safety Improvement Act (CPSIA) does include cadmium in their regulations, as well as other elements, like lead.   However, the regulations for lead include total content and soluble content.  Cadmium only has a soluble content regulation and that portion of the regulation (soluble content ASTM-F963) is currently under a stay for the general certificate of conformity and third-party approved testing.

    Consumer products are still required to be safe from the regulated metals, but the testing standards and certification process is on a little delay.

    What does this mean?  In my opinion, Washington State had it right when they wrote their children’s product safety act of 2008.  This act regulated both lead and cadmium in total content. 

    Additional, this is also another reason, in my opinion, to utilize X-Ray Fluorescence (XRF) analyzers  and how they can impact the CPSIA and help people and businesses know what is in their environment.  In one quick push of a button, of course with some proper training, you can non-destructively test for lead, cadmium, arsenic, mercury and other elements.  XRF analyzers are mobile, cost effective, efficient and accurate machines to identify a variety of heavy metals.

    One quick note…just because an item such as children’s jewelry may have a harmful metal such as lead or cadmium does not mean that that item will harm anyone.  But if that item does have lead or cadmium, it may be harmful and you should understand what is in your environment to mitigate harm.

    January 6, 2010

    Modification of HUDs Lead-Based Paint Inspection Certification Program can create CPSIA XRF Consumer Product Inspectors

    I believe that there is currently a system in place by the federal government that can be modified fairly easily to create XRF Consumer Product Safety Inspectors.  These inspectors can help businesses comply with regulation and reduce testing costs dramatically.  According to the Study on the Effectiveness, Precision, and Reliability of X-ray Fluorescence Spectrometry and Other Alternative Methods for Measuring Lead in Paint

    X-ray fluorescence (XRF) spectrometry has the potential to accurately measure lead content in painted films on children’s products at the limits required under the Consumer Product Safety Improvement Act (CPSIA) of2008, but appropriate standard reference materials (SRMs) and standard analytical methods need to be developed before a complete evaluation or determination is possible.

    Now the system that I’m referring to is from the U.S. Department of Housing and Urban Development.  I am currently a certified HUD Lead Inspector and Risk Assessor in the State of Washington.  In order for me to receive my certification, I had to first take a class and then pass a state exam (one as a lead inspector and a year later as a risk assessor)  You can review their guidelines here: http://www.hud.gov/offices/lead/lbp/hudguidelines/Ch07.pdf

    What I am suggesting is that with proper modification and adoption by the CPSC of Chapter 7 of the HUD (Lead-Based Paint Inspection), standard analytical methods can be developed.  I will even offer to assist with my experience and knowledge of consumer product testing using XRF analyzers.

    We have developed data collection methods, testing methods and procedures, analytical software solutions to verify if the elements found are truly present in the consumer product or not present.

    The HUD prefers to do a lead-based paint inspection by using XRF analyzers rather than destructive testing, like the CPSC. 

    Some advantages that XRF offers according to the CPSC include:

    1. XRF is often non-destructive (When we test we will even return your products tested to you)
    2. Little sample preparation is required, typically less than two minutes. 
    3. XRF can test small painted areas which is often difficult for ICP method (destructive testing)
    4. Handheld XRF analyzers are portable, allowing for field-screening of products.

    The CPSC did forget to mention the cost benefits of XRF verse ICP method.  On average, traditional testing using ICP-MS is in the range of $100.00 to $300.00 per color, per substrate, per test.  The costs we typically charge for XRF testing is in the range of $2.00 to $7.50 per color, per substrate, per test.

    Some disadvantages with XRF suggested by the CPSC include:
    1. XRF instruments do not readily measure in mass per units such as weight %, mg/kg or PPM and they have difficulty with quantification on a mass per mass unit basis.   (As a company are working on the quantification issue with software solutions and our XRF analyzers currently provides information in PPM among other measures)
    2. The source radiation can travel through the paint into the underlying substrate, leading to a measurement result that has contributions from both.  Special care needs to be taken in ascertaining the source of lead in any measurement.  (This is exactly what I am suggesting by creating standards and guidelines for consumer product testing, just like testing for lead in a home like the HUD requires, we can reduce or eliminate this issue.  Common Sense solves certain problems)
    3. XRF is matrix sensitive (This is true, but we are working on this as a company and we have never had a false positive for lead in any matrix and with proper software solutions and data this problem can be easily solved.  And if you forget about any quantification of the elements and just ask if they are there or not, XRF offers amazing opportunities to provide screening)
    4. There is currently no consensus industry standard test methods for quantifying lead on a mass per mass unit basis (We are here to help create this industry standard, if you look at the HUD chapter 7 as a basis for creation of standards, we can be started down the right path.  And with proper or industry standard for data collection, testing and analysis, this problem can be easily solved.)

    Here is the conclusion from the CPSC about XRF analysis:

    The ability of XRF to be used to accurately measure lead content in painted films on children’s products at the limits required under the CPSIA is currently limited due to the unavailability of SRMs and standard analytical methods. CPSC staff will continue to study the feasibility of using XRF technology for analyzing painted films on children’s products as SRMs and standard analytical methods become available.

    XRF technology is suitable in many cases for the accurate determination of lead in plastics provided appropriate test methods are followed, with the use of appropriate SRMs.

    All I am suggesting is that there is currently a system to provide elemental information specifically about lead by the U.S. Housing and Urban Development.  With proper modification of Chapter 7 of the HUD guidelines, the CPSC can create certified CPSIA Consumer Product Safety Inspectors who use X-Ray Fluorescence (XRF) Analyzers to test consumer products and more specifically children’s products regulated under the CPSIA.

    Would you want to see the creation of certified CPSIA XRF Consumer Product Safety Inspectors?

    What do you think about modification of HUDs chapter 7 to assist the CPSC with CPSIA consumer product testing?

    December 30, 2009

    Not intended for children 12 and under

    Has anyone noticed new labels or warnings on consumer products?  I was recently out shopping and began to notice that certain products are now being marked “Not intended for children 12 and under” or “Warning: Not intended for children age 14 and under.”

    Label "Not intended for children 12 and under"

    Label "Not intended for children 12 and under"

    I have a suspicion as to this reason and it has to do with the Consumer Product Safety Improvement Act (CPSIA) and an attempt to sidestep certain testing and certification requirements.

    Ok, I do have a certain advantage over most people; I do have access to an X-Ray Fluorescence (XRF) analyzer which provides elemental information (from 15 to 94 on the periodic chart) in a non-destructive testing method.  As an owner of an environmental technology company, Environmental Services & Solutions Corporation (Essco – Safety Check) we specializes in helping people know what is in their environment, we have provided consumer product testing for moms and dads, businesses and government.

    While recently testing, a few new items (specifically metal jewelry) were tested and these warning labels were present on the items.  The test results showed that cadmium was present in two separate items; one necklace was found (using XRF analyzers) to contain 118,988 PPM of cadmium or 11.89%, the other necklace 64,103 PPM of cadmium or 6.41%.

    I should mention that cadmium is one of the regulated elements within the CPSIA.  The regulation is based on a different testing method (typically ICP-MS) which is a testing methodology that uses acid to mimic ingestion.  The regulation for cadmium is based on soluble content limit and has a regulation of 75 PPM.  XRF is a total content testing method and is not capable of quantifying soluble content, but does look at total content. 

    Within this one piece of jewelry there appears to be 1586 times the level of cadmium found at the soluble content limit level.  I’m not going to suggest that the cadmium in this item has a soluble level greater than 75 PPM, however, cadmium is a very harmful element, is known to be a carcinogen and is present in this item.

    Are we to presume than an adult who purchases this item will ensure that a child never wears it?  You should note that just because an item has something potentially harmful, does not mean it will harm someone.  But that harmful element is present in the item and is a regulated element for children’s products.

    Is it ok for a manufacturer or importer to simply label a product “Not intended for children 12 and under” on an item, and thus sidestep testing?  Jewelry is handed down from mom to daughter; there are dress up days, girl’s night out, and many occasions that a young girl or boy for that matter will borrow moms or dads jewelry.

    But it appears not to just be jewelry and other consumer products are being marked in the same fashion, “Not intended for children 12 and under.”

    As I mentioned, I was out shopping recently, probably like most people around the holiday season.  I was out at a large retailer looking a knickknacks’ trying to decide on a few other gifts for family.  While shopping I picked up several other items that were merely decorative in nature (ornaments, figurines, ceramics, etc) and most were marked in the same fashion “not intended for children 12 and under.”  Several of these items were painted and there is regulation about lead in paint.

    Let me say, I did not buy any of these items so I cannot say that they have lead or other metals in them regulated under the CPSIA, however, it does make one think. 

    Why is an item now marked “not intended for children 12 and under?”  Is it to sidestep testing requirements for painted surfaces under the CPSIA?  Is it to sidestep testing requirement for children’s jewelry under the CPSIA?

    Let me see if I can break this down for everyone.

    Consumer products do contain a variety of elements and some of these elements are potentially harmful.  Particular elements are regulated for products designed and marketed to children 12 and under, as well as other safety standards.  Certain products that I have discussed including children’s jewelry and painted items have further requirements for testing including certification and specific testing methods. 

    Here is some general information on regulation:

    16 C.F.R. 1303 – Ban of Lead-Containing paint and certain consumer products bearing lead paint. Here is an excerpt from Sec. 1303.2 Definitions.

        (a) The definitions in section 3 of the Consumer Product Safety Act (15 U.S.C. 2052) shall apply to this part 1303.
        (b) For purposes of this part:
        (1) Paint and other similar surface-coating materials means a fluid, semi-fluid, or other material, with or without a suspension of finely divided coloring matter, which changes to a solid film when a thin layer is applied to a metal, wood, stone, paper, leather, cloth, plastic, or other surface. This term does not include printing inks or those materials which actually become a part of the substrate, such as the pigment in a plastic article, or those materials which are actually bonded to the substrate, such as by electroplating or ceramic glazing.
        (2) Lead-containing paint means paint or other similar surface coating materials containing lead or lead compounds and in which the lead content (calculated as lead metal) is in excess of 0.06 percent by weight of the total nonvolatile content of the paint or the weight of the dried paint film.

    Here is an excerpt from Section 3 of the Consumer Product Safety Act:

    SEC. 3. [15 U.S.C. 2052]
    (a) For purposes of this Act:
    (1) The term ‘‘consumer product’’ means any article, or component part thereof, produced or distributed (i) for sale to a consumer for use in or around a permanent or temporary household or residence, a school, in recreation, or otherwise, or (ii) for the personal use, consumption or enjoyment of a consumer in or around a permanent or temporary household or residence, a school, in recreation, or otherwise; but such term does not include—
    (A) Any article which is not customarily produced or distributed for sale to, or use or consumption by, or enjoyment of, a consumer, (there is more but for purposes of this conversation, they do not apply)

    On December 16th, 2009 the CPSC issued Interim Enforcement Policy on Component Testing and Certification of Children’s Products and other Consumer Products to the August 14th, 2009 Lead Limits.

    On August 14, 2009, the limit for lead in paint and similar surface coatings was reduced from 600 parts per million (ppm) to 90 ppm.

    Beginning on August 14, 2009, it became unlawful to sell, offer for sale, manufacture for sale, distribute in commerce or import into the United States any product that is subject to the new lead limits, but fails to comply, regardless of when the product was made.

    The testing and certification requirements for paint sold as such and for consumer products that are subject to the lead paint limits but are not intended primarily for children age 12 and younger (such as certain household furniture items) were stayed by vote of the Commission on January 30, 2009 (see 74 FR 6396 (February 9, 2009)). With respect to these products, the stay of enforcement relating to the lead in paint limit will be lifted as of February 10, 2010. Accordingly, such products, if manufactured after that date, will have to be certified to the 90 ppm limit based on a test of each product or a reasonable testing program (There was a second stay of enforcement on December 18th, 2009 which extended that stay one more year till 2/10/11)

    For consumer products that are not children’s products but are subject to lead paint limits (such as certain furniture items), a domestic manufacturer or importer may base its certification to the 90 ppm lead paint limit (when required as explained in paragraph 6 above) on its own testing of each paint used on the product, on testing by any third-party test lab, on paint certification(s) from any person or on a combination of these methods.

    What does all of this mean?   Simply, all consumer products that are painted are subject to the regulations of lead paint. It appears you can get around the certification and third party testing requirements by marking an item “not intended for children 12 and under.”  All painted consumer products still subject to the lead limit standards.

    As for jewelry (metal jewelry specifically), once again specific testing methods and certification are required for children’s jewelry, but if you label your products “not intended for use for children 12 and under” it appears a company can sidestep the certification and testing requirements. 

    Why is a harmful element like lead or cadmium present in the products we wear, eat off of, or our children play with is beyond my logic of thinking.  I’d like you all to think and begin to notice that more and more products appear to be labeled “not intended for children 12 and under”

    I can’t say if they contain lead or cadmium or other elements unless they are tested.  Manufacturers, importers and retailers are all suppose to ensure that the products they distribute meet safety regulations, but it appears that if you label your products “not intended for use by children 12 and under” you can side step particular testing and certification requirements.

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