#CPSIA - More Research
“Have you contacted your ink supplier. About 20 years ago the CPS mandated plastisol or ink for children’s garment be lead free. In the last few years they have all or mostly gone to Phalate free ink because of pressure from large customers like Nike, Russell and others. You should contact Union, Rutland or whoever you are using and get their certification for the ink. At least that should remove one of the costs.
If you contact SGIA, the person to contact is Johnny Shell their technical services director. This will be old news to them and they will have answers for you.
Good luck,
Scott Fresener”
His response made me think more clearly and the required testing for lead was no longer making sense. I read on the Fashion-Incubator-
“What must be tested: Lead
All sewn products intended for use of children 12 and younger must be unit tested for lead at this time. Lobbying groups are looking for exclusions for certain categories of goods like tee shirts. Toward the end of proving lead is not a dangerous element in kid’s apparel, I have been asked to make a request of you. If you have any lead or phthalate test results from a certified laboratory, please send them to me and I’ll pass them along.”
I made that phone call to SGIA (Specialty Graphic Imaging Association) and finally spoke with Marcia Y. Kinter Vice President - Government and Business Information. She has been following along and writing her own posts.
After explaining the situation of my business and asking how the cpsia would effect me she made it clear to me that apparel does not have a definitive yes or no answer to lead testing. She instead pointed me to the issue of Phthalates and referenced this pdf. We spoke of the section that discusses what can go inside the mouth of a child under three. If you are a parent you know that list is long. As I review my own product line, Happy Panda carries two styles of garments that would go in a child’s mouth, bibs and the sleeves of a gown. I could easily remove those from my line without a problem.
We also discussed the testing for lead in zippers, buttons, etc. She shared with me that she too would like more clarification and will be writing letters of her own before the holidays.
What does this mean? To me, it means that there is hope. I realize that petitions are great but we need to speak to the leaders in organizations within our own industry. I encourage you not to substitute our findings for your own but to inquire and find out what you can as it pertains to your own product.
These posts are based on my own product line and the information that I am obtaining as I read more and speak with leaders within my own industry. I need to research more to find out where Fashion-Incubator found their information about sewn products needing to be tested for lead. <Kathleen from Fashion-Incubator has left a comment below> My posts will always contain links for you to read what I find for yourself. If you have information that can be shared please leave me a comment. What’s my next step? I’m going straight to the written ACT!
Thank you,
Pamela Kramer
December 18th, 2008 at 6:26 pm
We could all breathe a big sigh of relief if Marcia Kinter were in charge of the decision making at the CPSC. At the risk of repeating myself, I attended a meeting on December 3rd in Washington DC with Cheryl Falvey, lead counsel for the CPSC and in charge of determining the rules of enforcement, testing and implementation and I watched and heard those words come right out of her mouth. Until otherwise specified, children’s products have to be tested for lead, even those that are inherently lead-free.
December 18th, 2008 at 7:26 pm
Thanks so much for all of your research! This could be such a devastating thing for all of us.
Question - I was informed by a fellow designer/friend that even if you printed/created the products before the effective date, all products are subject to being tested.
She also informed me that if you do a run of a design, have it tested, and later on do a separate run of the same design, it has to be tested again.
My question to you - what will you do with products that are already out there at stores?
Thanks for any insight.
December 19th, 2008 at 1:35 am
My company is doing a gift set for Home Shopping Network.com along with another company (that has already finished testing). When asked, I told them my products have not been tested and was told, “well, if the products were produced before Nov.18th 2008 then it will not be a problem.” I have not found any clear information on in stock inventory pre-regulation decision. I am also curious about how the government will seek proof of compliance, other than a testing certificate upon request. Will all items that pass testing need to have packaging stating it is “safe for children meeting CSPIA standards”? How will retailers know if they are getting product that has actually been tested? When i think of the implications of all these potential side costs I start to feel a little woozy.
December 19th, 2008 at 6:20 pm
While my company carries some products that I know are going to be affected by this Act (hair accessories, accessory/bow holders, and printed onesies), the majority of my product line deals with creative packaging of products produced by other manufacturers (diaper cakes/cupcakes, washcloth candies/lollies, layette milkshakes, baby cannolis/petit fours, etc…). Have you found anything in your research that would clarify whether I would have to have these types of items tested myself vs. obtaining copies of the certifications of the manufacturers whose products I use to put these goodies together? I have been unsuccessful in obtaining an answer to date and have been passed about, put on hold, and shuffled to more answering machines than I care to count!
Thanks for continuing to post!
BullfrogsandButterflies’s last blog post..Help Save Handmade Products!
January 7th, 2009 at 10:13 pm
I work for a branded apparel and accessories company in Indonesia, and some of our clothing is manufactured for children 12yrs and younger.
I’d just like to let people know that in Indonesia, there is already alot of awareness of the need to comply, esp for childrenswear, with these kind of regulations. Some EU countries (notably Germany) have been enforcing very similar requirements for some years already. Many medium to large Indonesian manufacturers have had orders returned cause of non-compliance, and know what materials they need to use and not use in order to comply. It’s only the small and small-medium suppliers that may have trouble understanding the requirements / verifying the quality of the products they are using in manufacturing processes.
I realise this does not help for US importers struggling with the new testing requirements, but obviously starting off with the right (complying) manufacturer is a big step in the right direction. Both in terms of business, and mankind in general
January 29th, 2009 at 6:23 am
Although this issue doesn’t effect our business yet…I have to wonder at the lunacy of this law/act. It wasn’t AMERICAN factories that caused this problem. It was those in China. I don’t understand why we’re being hit.
American factories have been safe in the past. Personally I don’t give a fig about the importers as this is where the problem began. Big businesses who care more about making more of a profit and taking jobs out of this country. I will never again buy from these larger companies who weren’t watching the stove as the pot boiled over. I don’t think I can ever trust them again.
I do care about all the small businesses that are going to be lost because of this poorly crafted law. Businesses that can’t afford to test every item they make by hand. Businesses that don’t have deep pockets.
I happen to like buying my grandchild toys and other items not made in large factories in China where it seems it’s ok to poison not only one’s own people but those you are selling to. I know I sound angry. But we almost lost our pets to the poisoned pet food that came out of China. I’m tired of worrying about what else won’t be found so I’m simply avoiding those products that are not made here or in countries that I can trust. I’ve even started asking where my pain meds are being made just because if they’re made in China I’ll need to find different meds. The same goes for the foods we buy. Items that do not have labeling will not be coming into our home. We are buying local foods as much as we can because we know what goes into them.
I understand the need for testing but I don’t understand why if the items you get to make something are certified to be ok the end product must be tested. At a time when American jobs are needed to keep our country afloat it seems counterproductive to create a law that will destroy the cottage industries that make up so many of those needed jobs.