Tuesday, August 2, 2011

100ppm of LEAD Now!

On July 13, 2011 the Commission (CPSC) voted (3-2) to accept the CPSC staff recommendation to lower the Lead content limits in substrates to the CPSIA statutory level of 100 parts per million (ppm).

The new total lead content limit, which is called for in the Consumer Product Safety Improvement Act (CPSIA), goes into effect on August 14, 2011 for manufacturers, importers, retailers and distributors of children's products.

Due to a stay of enforcement that is already in place until December 31, 2011, the CPSC will not enforce the CPSIA requirement for independent third party testing for total lead content. The stay of enforcement does not apply to children’s metal jewelry, which currently must undergo independent third party testing.

The rule applies to all materials in children’s products unless otherwise excluded under sections 16 CFR 1500.87 through 1500.91 of the Code of Federal Regulations, which address “inaccessible component parts”, exemptions for “certain electronic devices” and other “certain materials or products”, as well as procedures for requesting exemptions.

The new 100 ppm lead content limit is not applicable to inaccessible (internal) parts of children’s products and certain component parts of children’s electronic devices such as electronic connectors and plugs, including
headphone/earphone plugs.

Lead content levels for children's products are different from the levels Congress set for Lead in paint or surface coatings. The limit for lead in paint or surface coatings is .009 percent. The .009 percent level has been in place since August 14, 2009 and independent third party testing is required for all paints or surfaces coatings used on children's products.

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