Let me give a background on the Consumer Product Safety Improvement Act (CPSIA).
The CPSIA was signed into law by George W. Bush (Aug 2008) and was enacted February 10th, 2009. In its most simple form, the CPSIA regulates lead and other heavy metals in products designed and marketed to children 12 years of age or younger. As of today (11/30/09) the regulation for lead in total content is 300 Parts Per Million (PPM) in these products, there is a lower total lead content for painted surfaces at 90 PPM.
There is also the soluble content limit standards for; Antimony (60 PPM), Arsenic (25 PPM), Barium (1000 PPM), Cadmium (75 PPM), Chromium (60 PPM), Lead (90 PPM), Mercury (60 PPM) and Selenium (500 PPM) under ASTM F-963 at testing requirement for the CPSIA.
Under the CPSIA, firms must meet the total lead content for all children’s products in ADDITION to meeting F963 soluble limit for childrens products, as well as, phthalate standards (a chemical additive to plastics).
In most cases, the total lead content is the stricter standard, but in some cases it is possible that the F963 leachable limit will be the stricter standard. The scope of each is different, but where both are applicable, both are required. Indeed, CPSC has published methods for testing the total lead content of paint, metals and non-metals, and F963 contains the method for its prescribed soluble test.
I contacted the CPSC and specifically asked questions about both testing methods. In a response that I received from John Mullan of the CPSC, he said “It is required to meet both the total content limits of the CPSIA and the soluble content limits of ASTM F-963. CPSC has issued a number of standard operating procedures for measuring lead content in various substrates. There also are accreditation rules for labs measuring lead content and more will be coming out. If you want more info on this subject, please check our CPSIA website or write back to me. Thanks, J.G. Mullan”
Is any manufacture, importer, retailer actually having both tests done?
Currently, all testing methods associated with the CPSIA are destructive in nature, and multiple tests need to be performed for the total content of lead, and the soluble content of the eight elements, including lead.
X-Ray Fluorescence (XRF) technology is non-destructive and capable of testing for all eight elements simultaneously, with one test. XRF is only looking for total content, not the soluble content.
Soluble content testing essentially is a weak acid test to mimic digestion. However, the language of the CPSIA says that “total content by weight for any part of the product” is required, and the testing requirement ASTM F-963. ASTM F-963 is a testing method that provides information on the soluble content limits of the eight elements, not total content limit of lead.
The CPSC has issued testing methods for total lead in children’s jewelry and would apply to all children’s metal containing product. The CPSC has not yet issued a requirement for testing lead in non-metal products, due to the stay on testing (set to expire 2/10/10) and certification. However, they have issued a Standard Operating Procedure for testing for the total lead content in non-metal product. The CPSC has also issued Standard Operating Procedure for Determining Lead (Pb) in Paint and Other Similar Surface Coatings.
Simple Logic
XRF can test for all eight elements, simultaneously, non-destructively, efficiently and accurately (well, this part is somewhat debatable, but my company is working on software solutions to these pending problems). The biggest question is quantification; can XRF accurately quantify all the results? We say yes!
Let’s think about this logically for a second, if XRF can simply say if an element is present or not present (which it can do with spectrum analysis), we can take the quantification out of the equation for a second. If we perform a test on a children’s product and the elements (associated with ASTM F-963) are not present, why make a company do further, expensive destructive testing.
I’m in no way suggesting to get rid of the traditional testing methods; however, XRF is a perfect, simple, efficient, cost effective way to identify elements (our analyzers can detect 15 to 94 on the periodic chart) and we use spectral analysis to positively identify if they are present of not present.
If we do find the elements associated with the soluble limit standards, than further testing should be required.
But if we do not find the elements, than why make a company pay for expensive destructive testing?
Every time that a product is sent to a laboratory for testing they are destroyed, how is this impacting small businesses, the One of a Kind mom and pop manufacturer/retailer? They have to make two products and send one out for expensive testing, what will that do to their prices?
All I’m suggesting is to use some logic to help businesses reduce expenses, help them comply with regulation, help them ensure the safety of our children all while being proactive.
XRF can help identify all eight elements within the CPSIA regulations.
