Know what is in your environment

July 8, 2010

Free community testing for lead, cadmium and other heavy metals

Community Testing

Join us at Redmond Derby Days / IMPACT-Eco event this Saturday, July 10th, 2010 from 10:00AM to 6:00PM for FREE Consumer Product Testing.  Essco Safety Check will be providing FREE X-Ray Fluorescence (XRF) Testing for heavy metals; lead, cadmium, arsenic, mercury, antimony and more. 

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 this Saturday, July 10th, 2010 from 10:00 AM to 6:00PM 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.

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

    For more information about Redmond Derby Days and IMPACT / Eco-Fair, 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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    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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    March 3, 2010

    Parents and grandparents should be wary of the jewelry that you give your children or grandchildren.

    Parents and grandparents should be wary of the jewelry that you give your children or grandchildren. For over two years I have been operating an environmental technology company, providing X-Ray Fluorescence (XRF) testing for moms and dads, businesses, industry and government. Our desire is to help people and businesses “know what is in their environment” provide information, create jobs, stimulate business and improve lives.

    XRF testing is a non-destructive means to identify potentially harmful elements such as lead and cadmium in virtually anything and being an owner of such a company provides me with the ability to test the items that my family, specifically children, may come in contact with.

    Last week we gathered up some items that were given to my nieces by their grandmother and tested them using our equipment. With this knowledge you have the ability to make simple decisions that can mitigate potential harm.

    I tested several necklaces; some were brand new when given to my nieces and others were very old, my nieces great grandmothers. Testing results found lead levels over 30 percent in two of the charms on the necklaces; these charms also had antimony at close to 1 percent. I also found cadmium in a plastic beaded necklace over 7000 Parts Per Million (PPM) and lower amounts in other jewelry.

    Heavy metals found in these items

    Heavy metals found in these items

    Now just because these items had potentially harmful metals in them, doesn’t mean that they are going to harm my nieces. However, those metals are present in those items and the simple act of removing these items from “regular” use mitigates the potential harm. This doesn’t mean to throw these items out; this could create an environmental problem and some of these items are family heirlooms and should be kept and shared, when appropriate. However, if know what is in your environment, you can mitigate potential harm.

    So what can you do?

    You should be wary of the things you give your children or grand children. Make sure that your children, who are old enough to understand, don’t put these items in their mouth.

    In a blog written by CPSC Chairwoman Inez Tenenbaum:

    Because of these recent developments, I have a message for parents, grandparents and caregivers: Do not allow young children to be given or to play with cheap metal jewelry, especially when they are unsupervised…

    We have proof that lead in children’s jewelry is dangerous and was pervasive in the marketplace. To prevent young children from possibly being exposed to lead, cadmium or any other hazardous heavy metal, take the jewelry away.

    Parents should know that swallowing, sucking on or chewing a metal charm or necklace could result in exposure to lead, cadmium or other heavy metals, which are known to be toxic at certain levels of exposure.

    If you truly want to know what you may be giving your children or grandchildren, you could have these items tested by XRF analyzers, but there are costs involved to do XRF testing.

    Essco Safety Check will be offering FREE XRF testing on Saturday, March 20th, 2010 at South Park Community Center, 4851 South Tacoma Way at the Healthy Kids and Green Parenting Fair

     If you are would like to have any of your “family heirlooms” inspected for lead, cadmium or other heavy metals, please feel free to join us in Tacoma on March 20th.

    If you have any questions or comments, please let me know and i will try and answer your questions.

    March 2, 2010

    Daiso hit with $2.05 Million Civil Penalty for lead-laden toys

    Filed under: News, Regulation, viewpoint — Tags: , , , , , — Seth Goldberg @ 4:45 pm

    The Consumer Product Safety Commission has announced that the U.S. Subsidiaries of Daiso, a Japanese retailer, has agreed to pay a fine of $2.05 Million civil penalty and stop importing children’s products due to alleged violations of federal safety laws.  Daiso must also demonstrate to the CPSC that it has sufficient knowledge of and is in compliance of CPSC safety standards and testing requirements.

    Daiso California LLC and Daiso Seattle LLC have had a total of five recalls for 698 toys and other children’s products since 2008.  These recalls were for lead, phthalates, strangulation and choking hazards.  This is a relatively small number of products recalled compared to the several million recalled by Mattel in 2007, of which Mattel was only fined $2.3 Million.

    “This landmark agreement for the injunction sets a precedent for any firm attempting to distribute hazardous products to our nation’s children,” Commission Chairwoman Inez Tenenbaum said.  “We are committed to the safety of children’s products, and we will use the full force of our enforcement powers to prevent the sale of harmful products.”

    A senior executive at Daiso said the company accepts the fine and wants to make sure the products it imports are safe.

    I would recommend that Daiso utilize X-Ray Fluorescence (XRF) Analyzers as part of a reasonable testing/safety program to help determine if their products have harmful regulated metals such as lead or cadmium in their consumer products.   XRF Analyzers can help detect if elements are present of not present, they are non-destructive, accurate and a cost effective solution that can helping save businesses money while providing information that can ultimately lead to compliance with regulations.

    You can visit Daiso’s web page about their recalls at www.daisorecall.com

    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 30, 2010

    Lead & Cadmium found in Yellow Bumbo Seats

    Yellow Bumbo Seats

    Yellow Bumbo Seats

    Our main reason to start our business (Essco Safety Check) in 2007 was to help moms and dads know about the products that they and their children interacted with at home.  Essentially, we wanted to make sure that our children and family members were not exposed to harmful toxicants.  Some things have changed with our business model; expanding to help businesses, industries and government, but our premise is still the same, knowledge and awareness.

    At this same time we started Essco Safety Check, my nephew who was not even one years old was found to have small amounts of lead in his blood.  We immediately became detectives and began searching for the source of his blood lead levels.  Having an X-Ray Fluorescence (XRF) analyzer was an extreme advantage, we were able to rapidly narrow down the potential culprits. 

    By using the XRF analyzer, my brother was capable of identifying one specific item which his body came in direct contact with.  The likely culprit of my nephew’s blood lead levels was a Bumbo seat (a polyurethane seat a baby can sit in on the floor and wiggle around in but not get out of), specifically a yellow Bumbo seat.  This one item contained approximately 2000 parts per million (PPM) of lead and my nephew would sit in it, in a diaper, and chew on the sides of the seat.

    With this knowledge we simply removed the yellow Bumbo seat from his use and a few months later he was retested for lead in his blood and no lead was found.

    All of this was occurring at the end of 2007 and at that time there was no legislation about lead in children’s products other than painted surfaces, so the yellow Bumbo seat was legal.  Bumbo seats are not painted; they appear to have an integrated coloring.

    By April of 2008, Washington State had passed a new law, the Children’s Safe Products Act (CPSA), which regulated lead and cadmium in total content (this regulation has been preempted by newer federal regulation).  And in August of 2008, then President Bush signed the Children’s Product Safety Improvement Act (CPSIA) in to law which regulated heavy metals in children’s products.  With this new regulation lead is regulated for both total content and soluble content, all other elements within the regulation have a soluble content limit standard (this standard is currently voluntary for most children’s products, the Bumbo seat falls into this category).

    In May of 2008 I met with a few U.S. Consumer Product Safety Commission (CPSC) personal to go over some test results from new retail product testing, and general consumer product findings from the typical home inspection.  This data included children’s products found with lead and cadmium, including some children’s jewelry items and the yellow Bumbo seat that was my nephews and contained lead.

    In July of 2008, there was a national recall issued by the CPSC for one item we informed the CPSC about, it contained high quantities of lead.

    I’m going to jump ahead to June of 2009.

    I was hired to do an inspection on a house boat in Seattle to specifically look for lead.  This family had a young child who was diagnosed with lead in his blood, not at the action level, but enough to be concerned.  While testing in their home, I was discussing my story of how we got started as a business, my nephew and the yellow Bumbo seat.  The couple said, “We have a yellow Bumbo seat.”  I said, “Then I think we’ve found your culprit for lead in your child.” 

    They immediately brought me the yellow Bumbo seat to test; I tested it feeling confident I had solved this case.

    Using an XRF analyzer I tested the yellow Bumbo seat.  No lead was found, however cadmium was found present in the yellow Bumbo seat.

    I suggested that they remove the yellow Bumbo seat from their child’s use and potentially have their child’s blood tested for cadmium.

    I must say that in over two years of testing consumer products, specifically Bumbo’s, I’ve think I have tested every color Bumbo that they make.  I can say, in all my testing, I’ve never seen lead or cadmium in any other color, except yellow!

    A few months ago, I began assisting an AP reporter with data for an investigation of cadmium in children’s jewelry, I shared the same with him as I shared with the CPSC the prior year.  During our discussions about children’s products and heavy metals we have found, the yellow Bumbo seat was talked about.  We even tried to purchase new yellow Bumbo seats, but were not able to find any new yellow Bumbo’s in any retail store.  The only place we found yellow Bumbo seats for sale was on Ebay.com and craigslist.com, but those are used items and the CPSC appears to truly be only concerned about regulations for new products.

    As a company, we have decided to offer free yellow Bumbo seat screening.  Recently we had a concerned mom stop by our office with her beautiful young child and her yellow Bumbo seat.  We tested her yellow Bumbo with our XRF analyzer and did not find lead, but we found cadmium at approximately 2350 PPM.

    Is it a coincidence that when lead became regulated, that cadmium was found in its place?  Cadmium is a very harmful toxicant and a known carcinogen, but it is not regulated in total content like lead. 

    I have tested approximately a dozen yellow Bumbo seats since we started our business, I’ve most likely tested hundreds of all Bumbo seat colors.  These tests were done mostly at community events or in people’s homes who have hired us to test the consumer products testing.  In each and every case when testing a yellow Bumbo seat, lead was found, except for the last two I have tested (both mentioned in this article) which were found with cadmium. 

    I’m definitely not here to say that all yellow Bumbo seats are made contain lead or cadmium, but everyone that I have tested has been found with one of these harmful elements.  The mom who recently visited me to test her yellow Bumbo was very concerned and wondered why no one has been informed of this? 

    I can only speculate about this, I have not spoken to the manufacturing company, but questions can easily be raised.  Did they know about the lead in their products?  Do they know about cadmium in their products currently?  Where are all the new yellow Bumbo seats?  Why can’t I find a new yellow Bumbo seat on the market?

    I unfortunately start to think about moral and ethical questions surrounding this entire situation as well.  Who is more important the shareholder or the consumer?  Is it better to pay a fine then change manufacturing procedures?   What are the social and economic impacts of these heavy metals that our children are exposed to?

    To my knowledge, no recall was ever issued for this specific item. 

    I want to emphasize a few key things.

    First, just because a consumer product that your child is exposed contains a heavy metal, does not mean that that heavy metal will harm your child.  But since that harmful element is present it may cause harm. Simple awareness can mitigate this harm.

    Second, I honestly do not know if it is just coincidence about the timing of the metals with the yellow Bumbo seat.  Technically, there is nothing illegal about the yellow Bumbo with cadmium.  But once again, it is a harmful element and to mitigate exposure, mitigates harm.

    Third, I am honestly just trying to bring some awareness to this situation.  As I have mentioned, I have tested a variety of Bumbo seat colors, in my experience I have never seen lead or cadmium in any color, other than yellow.  All of these tests were tested with XRF analyzers. 

    Our company goal is to help people and businesses know what is in their environment.  Hopefully creating jobs and improving lives; reducing business expenses and helping businesses comply with regulation; most importantly, providing knowledge and awareness.

    If you have a yellow Bumbo seat and are close enough to visit our office, please contact us at info@essco-safetycheck.com or call us at 425-749-4136 to set up an appointment.  We will be happy to test your yellow Bumbo seat for free.  Feel free to contact us if you have any questions.

    January 29, 2010

    Children’s necklaces recalled due to high levels of cadmium

    Essco Safety Check played a small role in this recall; we initially assisted the Associated Press with data and information from over two years of testing consumer products using our XRF analyzers.  Our data, along with data from HealthStuff.org lead the AP to do an investigation about cadmium in children’s jewelry.  That investigation has lead to this recall.

    Today, January 29, 2010, the US Consumer Product Safety Commission announced a voluntary recall of children’s metal necklaces.  In corporation with F.A.F. of Greenville, R.I. about 55,000 units were recalled. 

    The products recalled are shaped as a frog pendant or metal crown on a metal chain necklace.  The model #’s are 4616-4187 & 4616-4190 with UPC #’s 72783367144 & 72783367147

    Children's jewelry recalled

    Children's jewelry recalled

    These items were sold exclusively at Wal-Mart retail stores nationwide from November 2009 through January 2010 for approximately $5.

    It is recommended that consumer immediately remove these recalled items from children.  Please take all the recalled jewelry to any Wal-Mart retail store for a full refund or a free replacement product.

    For those of you who wish to further contact F.A.F or additional information, please call F.A.F Inc at 1-800-949-3311 between 8 am and 4:30 pm ET Monday – Friday or visit www.faf.com

    January 22, 2010

    The Potential Economic Impact of the Consumer Product Safety Improvement Act

    This is an objective view of how the Consumer Product Safety Improvement Act (CPSIA) is potentially affecting small businesses, the testing costs and methods, as well as a common sense approach to certification and job creation.

    The CPSIA was written in 2008 to ensure that children’s products don’t contain harmful amounts of certain elements, like lead and cadmium.  All children’s products must eventually be certified by an accredited 3rd party laboratory who utilizes specific testing methods.  With these laboratory results a company can create the required general certificate of conformity (GCC).

    There is also a stay of enforcement with the CPSIA until 2/10/11 for the GCC on all children’s products other than those that are painted, children’s jewelry, cribs or pacifiers.  Additionally, there is regulation in total content of lead and regulation in soluble content for eight elements (including lead), this method (soluble) ASTM F-963 is currently voluntary.  There is also regulation for the amount of certain phthalates, a chemical added to plastics to make them softer.

    All current approved testing methods are destructive, they are very costly, can take extensive periods of time to get results.  This testingcan only done by a select group of laboratories (only 227 worldwide and 60 within the United States, many of these labs have one parent company). 

    While researching this article, I attempted to find an economic impact analysis that was performed for CPSIA, but was unable to find one.  I even contacted a state representative with Washington State, in April 2008, four months prior to the federal CPSIA regulation, Washington State passed the Children’s Product Safety Act, but apparently no impact study was done either.

    How does one figure out the economics behind this piece of legislation? 

    I thought to try and simplify things and try to figure out how many businesses would be impacted, what size of business they are and ultimately how products that would be affected.  I will compare an approximate cost of traditional testing methods, to a technology that is mobile and non-destructive (X-Ray Fluorescence).  And I will show how many jobs could be potentially created. 

    Number of businesses potentially affected by the CPSIA

    Businesses that are potentially affected by the CPSIA include; Manufacturers, importers, retailers, charities and re-sellers who make, distribute in commerce, children’s products, those designed and marketed to children 12 and under.

    I found two main sources for this data, the US Census and the North American Industry Classification System (NAICS).  The US Census numbers were from 2006 and the numbers from the NAICS are from 2009.

    Here is data from the North American Industy Classification System (NAICS)  their data was used to calculate the number of potentail businesses affected by the CPSIA.

    Total number of manufacturers potentially affected by the CPSIA in the United States 52,544***
    Total number of wholesalers potentially affected by the CPSIA in the United States 125,624***
    Total number of retailers potentially affected by the CPSIA in the United States 511,240***
    Total number of businesses potentially affected by the CPSIA according to the NAICS 689,408***

    The US Census provided data on the size of the businesses affected and is broken down by percentage.  My use and definition of small business is based on <500 employees, however, I include data on 0-4 employees and <20, this data is based only on the businesses potentially affected by the CPSIA.

    Total Manufacturers potentially affected have 0-4 employees 46.3%, <20 employees 78.7% and <500 employees 97.4%*** (these are cumulative totals)
    Total Wholesalers potentially affected have 0-4 employees 54.1%, <20 employees 79.7% and <500 employees 94.8%*** (these are cumulative totals)
    Total Retailers potentially affected have 0-4 employees 37.9%, <20 employees 56.9% and < 500 employees 65.7%*** (these are cumulative totals)
    Average for all businesses potentially affected by the CPSIA have 0-4 employees 40.2%, <20 employees 60.8% and <500 employees 70.9%*** (these are cumulative totals)

    What does all of this mean?  More small businesses are going to be affected by this regulation than large businesses.  40% of all businesses potentially affected by the CPSIA are very small with only 0-4 employees. 61% of all businesses potentially affected by the CPSIA have less than 20 employees.  All businesses classified as small businesses, less than 500 employees, 71% of them potentially will be affected by the CPSIA.

    Number of products potentially needing testing

    Attempting to figure out the amount of SKUs or total products potentially affected was an even larger task than trying to figure out the number of businesses potentially affected.  There is no single source of data about the number of products manufactured or sold, so I took a slightly different approach.  I researched a few key consumer websites and contacted a few experts to make my assumptions.

    Yes, I said assumptions.  The problem with figuring out some specifics is that I’m guessing on a few key points.  Here we go!

    I first visited ETSY.com.  ETSY.com is a website that sells handmade consumer products, you know, made by your friends and sold online.  When I looked on their site earlier this week, they had over 280,000 children’s products listed.

    I decided to go to two other major consumer product retail sales websites, Buy.com and Amazon.com.  At Buy.com when I tallied all the potential products that could be affected by the CPSIA I found over 66,000 different products.  On Amazon.com the amount was much more.  I will add one caveat, at amazon.com they did not separate jewelry into a product category “children’s jewelry” so I used the total of all jewelry in my tally.  With all jewelry listed and all other products I found that could be potentially affected by the CPSIA, the total was almost 1.18 million products on Amazon.com.  Without the jewelry the total was over 150,000 products.

    In a conversation I had with a regulatory agency employee in the State of Washington, she suggested that the total number of potential products on the market is in the tens of millions.

    Based on these numbers and suggestions, I’m going to split the middle and suggest that there are five million different products on the market that could be impacted by the CPSIA.

    The Cost Breakdown

    First we need to look at the traditional testing methods.  I’m only going to look for three things, amount of lead, amount of cadmium and phthalate testing (traditionally this is tested using a Gas Chromatography machine).  For this analysis, disregard all other potential costs.

    Traditional ICP-MS testing for heavy metals can easily be hundreds of dollars per test, per color, per substrate.  I have been quoted ranges from $75 to $300 per test for heavy metal testing; phthalate testing has been a bit lower from $75 to $150.  For this comparison, I’m going to use the low end of $75 per test.

    I am also going to assume that every item needs to be tested a total of five times.  Every product is a little be different, they’re made with different colors, different substrates and materials.  Take an old childhood favorite Rubik’s Cube.  It has six different colors and is made of one substrate (black plastic), that item would require a minimum of seven tests.  As I said, I’m going to use a five test average.

    If there are five million items and each has to be tested five times, that is a total of twenty-five million tests.  Considering we are looking for three things (lead, cadmium and phthalates at $75 per test) the total for traditional testing methods would be $5.625 billion.

    If all the accredited laboratories split this testing evenly, that would be approximately $25 million per lab worldwide.

    Other testing method

    There is a technology that is mobile and non-destructive that can simultaneously look for lead, cadmium and PVC in one simple push of the button.  Unfortunately, it is not the approved testing method for the CPSIA.

    This technology is called X-Ray Fluorescence (XRF) and is readily available to use for consumer product testing.  It is the approved testing source for HUD Lead inspections, and is used by the EPA, FDA and CPSC.

    Data that I have collected from over 8000 test results using XRF analyzers shows that of all consumer products tested only 16.3% are found with any amount of lead, 4.3% are found with any amount cadmium and 11.1% are identified to be made of PVC.  In total only 31.7% of all consumer products I have tested using XRF analyzers have been found with lead, cadmium or PVC, yet all products are required to be tested destructively.

    I used these percentages to help figure out the comparable numbers.

    Comparison

    If all products are tested by traditional testing methods using ICP-MS and GC machines the cost for testing for lead, cadmium and PVC would be $5.625 billion.  However, if you were to use XRF analyzers to screen all these products, at a cost average of $5.00 per test the total cost would be $125 million. 

    At this point, all items that tested positive for lead, cadmium or PVC should be further tested by the traditional testing methods.  Using the percentage of items found with lead, cadmium or PVC (31.7%) traditional testing methods would cost $1.784 billion.  If you add up the XRF screening and then the re-testing by traditional testing methods, the costs would be approximately $1.9 billion. 

    That would be a cost savings of $3.7 billion or 66.1% for consumer product testing for the CPSIA.

    That is a tremendous amount of money that these businesses can put back to work in our economy, hiring people, investing, building business all while keeping compliant with the regulations.

    Number of jobs created

    I’m going to specifically look at this as the formation of XRF Certified Consumer Product Inspectors.  If a total of twenty-five million tests need to be done annually, and each inspector can do two hundred tests per day, two hundred and fifty days per year, that could create five hundred jobs.  That is not including managers and office staff to handle additional work.  Overall, I would suspect that close to one thousand jobs could be created, but that is only based on five million products that need to be tested.

    What if that total number is closer to twenty million?  That would potentially be upwards of four thousand jobs and a potential economic impact of close to $15 billion going back in to the pockets of businesses of which almost 71% are considered small businesses.

    Conclusion

    What I’m suggesting is a common sense approach to testing and the certification that consumer products meet the regulations of the CPSIA.  If XRF testing is approved to simply screen products for certain heavy metals and PVC, and only those found to contain these elements or chemicals would be further tested, there can be a huge positive economic impact for small businesses, as well as the creation of jobs.

    ***These figures were calculated from two sources, the US Census and the NAICS.

    January 10, 2010

    AP IMPACT: Toxic Metal in Kids’ Jewelry From China

    Here is an article written January 10th, 2010 by Justin Pritchard, Associated Press Writer, that my company is mentioned in.

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    via AP IMPACT: Toxic Metal in Kids’ Jewelry From China – ABC News.

    Barred from using lead in children’s jewelry because of its toxicity, some Chinese manufacturers have been substituting the more dangerous heavy metal cadmium in sparkling charm bracelets and shiny pendants being sold throughout the United States, an Associated Press investigation shows.

    The most contaminated piece analyzed in lab testing performed for the AP contained a startling 91 percent cadmium by weight. The cadmium content of other contaminated trinkets, all purchased at national and regional chains or franchises, tested at 89 percent, 86 percent and 84 percent by weight. The testing also showed that some items easily shed the heavy metal, raising additional concerns about the levels of exposure to children.

    A spokesman for the U.S. Consumer Product Safety Commission, which regulates children’s products, said Sunday that the agency “is opening an investigation” and “will take action as quickly as possible to protect the safety of children.”

    Cadmium is a known carcinogen. Like lead, it can hinder brain development in the very young, according to recent research.

    Children don’t have to swallow an item to be exposed — they can get persistent, low-level doses by regularly sucking or biting jewelry with a high cadmium content.

    To gauge cadmium’s prevalence in children’s jewelry, the AP organized lab testing of 103 items bought in New York, Ohio, Texas and California. All but one were purchased in November or December.

    The results: 12 percent of the pieces of jewelry contained at least 10 percent cadmium.

    Some of the most troubling test results were for bracelet charms sold at Walmart, at the jewelry chain Claire’s and at a dollar store. High amounts of cadmium also were detected in “The Princess and The Frog” movie-themed pendants.

    “There’s nothing positive that you can say about this metal. It’s a poison,” said Bruce A. Fowler, a cadmium specialist and toxicologist with the U.S. Centers for Disease Control and Prevention. On the CDC’s priority list of 275 most hazardous substances in the environment, cadmium ranks No. 7.

    Jewelry industry veterans in China say cadmium has been used in domestic products there for years. Zinc, the metal most cited as a replacement for lead in imported jewelry being sold in the United States, is a much safer and nontoxic alternative. But the jewelry tests conducted for AP, along with test findings showing a growing presence of cadmium in other children’s products, demonstrate that the safety threat from cadmium is being exported.

    A patchwork of federal consumer protection regulations does nothing to keep these nuggets of cadmium from U.S. store shelves. If the products were painted toys, they would face a recall. If they were industrial garbage, they could qualify as hazardous waste. But since there are no cadmium restrictions on jewelry, such items are sold legally.

    The CPSC has cracked down on the dangers posed by lead and products known to have killed children, such as cribs, it has never recalled an item for cadmium — even though it has received scattered complaints based on private test results for at least the past two years.

    There is no definitive explanation for why children’s jewelry manufacturers, virtually all from China in the items tested, are turning to cadmium. But a reasonable double whammy looms: With lead heavily regulated under the Consumer Product Safety Improvement Act of 2008, factories scrambled for substitutes, just as cadmium prices plummeted.

    That law set a new, stringent standard for lead in children’s products: Only the very smallest amount is permissible — no more than 0.03 percent of the total content. The statute has led manufacturers to drastically reduce lead in toys and jewelry.

    The law also contained the first explicit regulation of cadmium, though the standards are significantly less strict than lead and apply only to painted toys, not jewelry.

    To determine how much cadmium a child could be exposed to, items are bathed in a solution that mimics stomach acid to see how much of the toxin would leach out after being swallowed.

    The jewelry testing for AP was conducted by chemistry professor Jeff Weidenhamer of Ashland University in Ohio, who over the past few years has provided the CPSC with results showing high lead content in products that were later recalled. His lab work for AP assessed how much cadmium was in each item. Overall, 12 of the 103 items each contained at least 10 percent cadmium. Two others contained lower amounts, while the other 89 were clean.

    Ten of the items with the highest cadmium content were then run through the stomach acid test to see how much would escape. Although that test is used only in regulation of toys, AP used it to see what hazard an item could pose because unlike the regulations, a child’s body doesn’t distinguish between cadmium leached from jewelry and cadmium leached from a toy.

    “Clearly it seems like for a metal as toxic as cadmium, somebody ought to be watching out to make sure there aren’t high levels in items that could end up in the hands of kids,” said Weidenhamer.

    The CPSC reacted swiftly to the AP story. Agency spokesman Scott Wolfson said: “CPSC will open an investigation into the products tested by Professor Weidenhamer, who we have worked closely with before.” He said CPSC would study Weidenhamer’s results, attempt to buy the contaminated products content and “take appropriate action as quickly as possible.”

    Weidenhamer’s test results include:

    — Three flip flop bracelet charms sold at Walmart contained between 84 and 86 percent cadmium. The charms fared the worst of any item on the stomach acid test; one shed more cadmium in 24 hours than what World Health Organization guidelines deem a safe exposure over 60 weeks for a 33-pound child.

    The bracelet was purchased in August 2008. The company that imported them, Florida-based Sulyn Industries, stopped selling the item to Wal-Mart Corp. in November 2008, the firm’s president said. Wal-Mart would not comment on whether the charms are still on store shelves, or how many have been sold.

    Sulyn’s president, Harry Dickens, said the charms were subjected to testing standards imposed by both Wal-Mart and federal regulation — but were not tested for cadmium.

    In separate written statements, Dickens and Wal-Mart said they consider safety a very high priority. “We consistently seek to sell only those products that meet safety and regulatory standards,” Wal-Mart said. “Currently there is no required cadmium standard for children’s jewelry.”

    As was the case with every importer or retailer that responded to AP’s request for comment on the tests, neither Sulyn nor Wal-Mart would address whether the results concerned them or if the products should be recalled.

    — Four charms from two “Rudolph the Red-Nosed Reindeer” bracelets sold at a Dollar N More store in Rochester, N.Y., were measured at between 82 and 91 percent cadmium. The charms also fared poorly on the stomach acid test. Two other charms from the same bracelets were subjected to a leaching test which recreates how much cadmium would be released in a landfill and ultimately contaminate groundwater. Based on those results, if the charms were waste from manufacturing, they would have had to be specially handled and disposed of under U.S. environmental law. The company that imported the Rudolph charms, Buy-Rite Designs, Inc. of Freehold, N.J., has gone out of business.

    — Two charms on a “Best Friends” bracelet bought at Claire’s, a jewelry chain with nearly 3,000 stores in North America and Europe, consisted of 89 and 91 percent cadmium. The charms also leached alarming amounts in the simulated stomach test. Informed of the results, Claire’s issued a statement pointing out that children’s jewelry is not required to pass a cadmium leaching test.

    “Claire’s has its products tested by independent accredited third-party laboratories approved by the Consumer Product Safety Commission in compliance with the commission’s standards, and has passing test results for the bracelet using these standards,” the statement said. Those standards scrutinize lead content, not cadmium.

    — Pendants from four “The Princess and The Frog” necklaces bought at Walmart ranged between 25 and 35 percent cadmium, though none failed the stomach acid test nor the landfill leaching test. The Walt Disney Co., which produced the popular animated movie, said in a statement that test results provided by the manufacturer, Rhode Island-based FAF Inc., showed the item complied with all applicable safety standards.

    An official at FAF’s headquarters did not respond to multiple requests for comment when informed of Weidenhamer’s results; a woman at the company’s office in southern China who would not give her name said FAF products “might naturally contain some very small amounts of cadmium. We measure it in parts per million because the content is so small, for instance one part per million.” However, the tests conducted for AP showed the pendants contained between 246,000 and 346,000 parts per million of cadmium.

    “It comes down to the following: Cadmium causes cancer. How much cadmium do you want your child eating?” said Michael R. Harbut, a doctor who has treated adult victims of cadmium poisoning and is director of the environmental cancer program at the Karmanos Cancer Institute in Detroit. “In my view, the answer should be none.”

    Xu Hongli, a cadmium specialist with the Beijing office of Asian Metal Ltd., a market research and consultancy firm, said test results showing high cadmium levels in some Chinese-made metal jewelry did not surprise her. Using cadmium alloys has been “a relatively common practice” among manufacturers in the eastern cities of Yiwu and Qingdao and the southern province of Sichuan, Xu said.

    “Some of their products contain 90 percent cadmium or higher,” she acknowledged. “Usually, though, they are more careful with export products.”

    She said she thought that manufacturers were becoming aware of cadmium’s dangers, and are using it less, “But it will still take a while for them to completely shift away from using it.”

    The CPSC has received dozens of incident reports of cadmium in products over the past few years, said Gib Mullan, the agency’s director of compliance and field operations. Though the CPSC has authority to go after a product deemed a public danger under the Federal Hazardous Substances Act — the law used in lead-related recalls several years ago — there have been no enforcement actions.

    “We are a small agency so we can’t do everything we think would be a good idea. We have to try to pick our spots,” Mullan said. At most, the agency can investigate 10 percent of the tens of thousands of reports filed by the public each year, he said.

    With the help of an outside firm, the CPSC has started a scientific literature review of cadmium and other heavy metals, including how the substances fare in leaching tests, according to spokesman Wolfson. “If there has a been a shift in manufacturing to the use of cadmium, CPSC will take appropriate action.”

    Meanwhile, the CPSC’s Mullan cites “a trend upward” in cadmium reports the agency has received — and private-sector testing AP reviewed shows cadmium is showing up more frequently.

    Two outfits that analyze more than a thousand children’s products each year checked their data at AP’s request. Both said their findings of cadmium above 300 parts per million in an item — the current federal limit for lead — increased from about 0.5 percent of tests in 2007 to about 2.2 percent of tests in 2009. Those tests were conducted using a technology called XRF, a handheld gun that bounces X-rays off an item to estimate how much lead, cadmium or other elements it contains. While the results are not as exact as lab testing, the CPSC regularly uses XRF in its product screening.

    Much of the increase found by the Michigan-based HealthyStuff.org came in toys with polyvinyl chloride plastic, according to Jeff Gearhart, the group’s research director. Both lead and cadmium can be used to fortify PVC against the sun’s rays. Data collected by a Washington-based company called Essco Safety Check led its president, Seth Goldberg, to suspect that substitution of cadmium for lead partly explains the increase he’s seen.

    Rick Locker, general counsel for the Toy Industry Association of America, and Sheila A. Millar, a lawyer representing the Fashion Jewelry Trade Association, said their industries make products that are safe and insisted cadmium is not widely used.

    Millar said jewelry makers often opt for zinc these days. “While FJTA can only speak to the experience of its members,” Millar wrote in an e-mail, “widespread substitution of cadmium is not something they see.”

    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?

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