Typical household consumables
Most people would think that the “products” you and your children use every day in your daily routine are “consumer products”, you know the things we cook, eat and drink with. Most people would think that “products” put in your mouth, given to us or used on us by a hospital while we are patients, are tested for lead and other harmful chemicals. Most people would think that the regulating agencies are fully protecting us and inspecting all “products.” Most people would be wrong!
A “consumer product” is regulated by the US Consumer Product Safety Commission (CPSC) and their definition of a consumer product is:
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;
There are some exemptions that we will get to in a moment.
According to the CPSC, they are “charged with protecting the public from unreasonable risks of serious injury or death from thousands of consumer products and they are committed to protecting consumers and families from products that pose a fire, electrical, chemical, or mechanical hazard or can injure children.” Essentially, the CPSC is working to ensure the safety of consumer products from harming the public.
Why are some “products” that consumer’s use on a regular basis not considered “consumer products”? Why are these “products” not regulated or tested for heavy metals and chemicals as a children’s product would be? Why are these “products” regulated by different governmental agencies? And why do those agencies have different ways of testing and regulating for lead?
Simply put, why do we permit lead and other harmful elements and chemicals into our “consumer” and “non-consumer products”?
Why does the FDA, which regulates all food surface contact points, have a different testing regulation for lead than a child’s product? Doesn’t a child eat off of a typical dinner plate, and drink hot chocolate out of a standard coffee cup? Why is a product that we all put into our mouth, not tested for lead?
Because these “products” are not considered “consumer products” and ultimately not “children’s products” which means that they are not required to be tested for lead or phthalates. You may want to ask your legislator!
Here are a few examples of items that you may think are “consumer products” but in fact are not considered “consumer products” and thus not regulated by the CPSC. These “products” can all be used by children, all have a potential for direct epidermal contact or direct ingestion potential. In each case, these products are regulated by the Food & Drug Administration (FDA) and some have regulations for lead and others do not, but none are regulated for “total content” of lead and thus are all permitted to have more than 300ppm of lead (the legal amount of lead in a toy “children’s product”).
1. Toothbrushes
2. Toothpicks
3. Dental Floss
4. Band Aides
5. Bulb Syringes
6. Surgical Tubing
7. Flatware (Knives, forks, baby spoons, serving utensils, etc…)
8. Ceramics (plates, cups, bowls, etc)
9. Cutting boards
10. Pots, pans and other cooking utensils.
There whole crux of this is that there is no real definition of a “consumer product.” Most people would think that a toothbrush is a consumer product and since children use toothbrushes, they would be inspected for lead. Most people would be wrong!
Toothbrushes and other patented early intervention dental products which are designed or intended for children 12 years of age or younger are in fact, not “consumer products” and because these products are not “consumer products” they do not fall within the definition of children’s products that require third-party testing. Thus the lead limits in the Consumer Product Safety Improvement Act (CPSIA) do not apply to this product.
Have you considered what is in your plates, dishes or your coffee cups? Do you know that FDA regulates the food contact surface of a coffee cup and the CPSC regulates the exterior, non-food contact surface?
How is this protecting the public?
Environmental Services & Solutions Corporation (Essco Safety Check) is here to help bring awareness and share information about environmental concerns. Feel free to visit our website for more information www.essco-safetycheck.com
Keep you eyes out for “Part 2″ of this story, more specific information on State and Federal regulations.
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