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.

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.

Know what is in your environment!