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?
