Report on STR CPSIA Webinar

The testing company STR put together a webinar to help people navigate the CPSIA (and sell their services, of course). It’s the best webinar I’ve seen, and has one interesting tidbit of vast importance to those needing to submit products to test.

On page 18, called “Traceability, Traceability, Traceability” (ain’t that the truth), they say (in PowerPointese):

• CPSC Policy to test on Final Product ONLY
• No Composite Testing for Children’s Products
How can one wrap their financial arms around this testing required?
• Buttoned Up Traceability Records
• Allows for testing on a single finished product even if that same
material is used for different SKUs – Eliminate Redundant Testing (emphasis mine)

We have heard this same statement now from another lab, NSF. They use the following Q and A from the CPSIA FAQ to justify this:

Q: Is compositing allowed for testing for lead in the surface paint/coating or in the substrates (that is the underlying materials that are painted or coated)?

A: The term “compositing” could refer to more than one type of combination. One type of compositing that labs have used is to combine like paint from several like parts or products to obtain a sufficient sample size for analysis where there is not sufficient quantity of paint on one item to perform the testing. This is appropriate in this circumstance and may even be necessary to obtain valid analytical results.

Another type of compositing is to combine different paints or substrates from one or more samples to reduce the number of tests run. This type of composite testing may fail to detect excessive levels of lead in one individual paint or substrate because they have been diluted. This approach is therefore not acceptable.

What this means is that if you make more than one item from the same materials, (say a white onesie and a white infant T-shirt) and you submit them for testing at the same time, then they will test the identical components once. So, in our example, the white fabric (if identical) would be tested (for lead, flammability, and phthalates) once and used to certify both items. Conceivably, if they were both embellished identically, you could get away with three tests (fabric, screen print, and snaps), rather than 5 tests (2x fabric, 2x screen print, 1x snaps on onesie). If you have a lot of SKUs in your line, this could quickly add up.

There is solid precedence for this. When testing baby carriers for heavy metals and flammability, it’s common to submit, say, three colorways of an identical carrier. The lab will add up all of the unique components represented in the three carriers and test each one. So, one test each for the webbing, buckles, and batting, then one test each for each fabrication/colorway combination (black canvas, black twill, blue canvas, blue twill, brown canvas, brown twill).

We are still hoping to be allowed to use component testing, and supplier certifications of components. But this is good news, nonetheless. Get organized and submit your products for testing in one big batch, so you can minimize your testing costs. Be sure to ask your testing lab if they will be using this strategy before you send them your products!

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