Lead and ASTM F963 Elements: Workshop on Potential Ways To Reduce Third Party Testing Costs Through...

U.S. Consumer Product Safety Commission

Workshop on Potential Ways To Reduce Third Party Testing Costs Through Determinations

Consistent With Assuring Compliance

April 3, 2014

This presentation was prepared by CPSC staff, has not been reviewed or approved

by, and may not reflect the views of, the Commission.

US CONSUMER PRODUCT SAFETY COMMISSION

Disclaimer

This presentation was prepared by CPSC staff, has not been reviewed or approved by, and may not reflect the views of, the Commission.

The views and opinions expressed by public participants during this workshop are those of the participants and do not represent official government policies or positions of the Commission or its staff.

This workshop is being webcast and recorded. Please identify yourself when speaking.

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LEAD AND ASTM F963-11 ELEMENTS

Moderator: Patricia Adair

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Lead

Commission determined materials that do not exceed 100 ppm lead content, and are not subject to third party testing• 16 CFR 1500.91

Procedures and requirements for lead content determinations• 16 CFR 1500.89

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Lead

For manufactured materials, what specific information and data should staff assess in considering a recommendation that the material’s production does not, and will not, result in a lead content above 100 ppm?

How lead in the recycling stream can be kept from rendering a material noncompliant?

How the potential for contamination is addressed by all manufacturers of a material?


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Lead

What specific information and data staff should obtain to be assured that continued production of a material, regardless of its origin, will continue to be compliant with the lead content limit without requiring third party testing?

What other information the staff should consider before potentially making recommendations to the Commission regarding a determination for lead content?


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Lead

What changes would you recommend to improve the procedures of 16 CFR 1500.89 in furtherance of the Commission’s specific determinations related direction to staff? What additional specific information and data should staff assess in considering a recommendation that a determination be made that a material intrinsically does not, and will not, contain lead above 100 ppm? Is this information obtainable?


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Lead

What additional lead determinations would provide the greatest cost savings, assuming that the determinations have a satisfactory legal and evidentiary basis and are adopted by the Commission?


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ASTM F963-11 Elements

A possible determination could identify materials that do not, and will not, contain the eight elements listed in the Toy Standard, either with respect to chemical content or to solubility of the elements at levels that do not exceed the allowable limits.

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Which materials, by their nature, do not, and will not contain any of the eight elements in content above their solubility limits?

Which materials have a solubility of all seven elements other than lead that is low enough for a determination to possibly be recommended that the material will comply with ASTM F963–11, regardless of the elements’ content levels (lead content must not exceed 100 ppm for substrates, and 90 ppm for surface coatings)?


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How can compliance with the solubility limits of the elements other than lead be inferred from content measurements, irrespective of the shape or other physical characteristics of the material as a component part of a toy?


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Which materials would present the greatest cost reduction if the Commission determined that third party testing is not required, especially considering that compliance with the underlying standard(s) would still be required?

What other information staff should consider before potentially making recommendations to the Commission regarding a determination of compliance with the limitations on the eight elements listed in the Toy Standard?


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Panel Participants

Nikki Brown, Penn State University Bill Perdue, American Home Furnishings Alliance Mark Fellin, Juvenile Products Manufacturers

Association Al Kaufman, Toy Industry Association Hailey Mann, American Plastic Toys Sanjeev Gandhi, SGS Consumer Testing Services


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Hailey Mann – Lead/ASTM Panel

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• Thank you for the opportunity to participate on this panel.• I would like to introduce American Plastic Toys, Inc. (APT)

We are a domestic toy manufacturer of injection molded plastic toys. The company was founded in 1962 and has operated continuously for over 50 years. Our corporate headquarters is located in Walled Lake, Michigan.

• The following provides a brief description of company operations and position in the toy industry.

American Plastic Toys Inc.

American Plastic Toys CPSC Lead/ASTM Panel 31


Operations:APT currently has five buildings with over 1,000,000 square feet of operational and storage space company wide. All of our products are produced and all shipments originate from either Walled Lake, Michigan or Olive Branch, Mississippi. We are vertically integrated, taking in raw plastic resin and colorants, and molding and assembling the finished toys. We have over 50 injection-molding machines of various sizes and over 300 employees.

Product Line:APT has the most comprehensive line of injection molded toys in the United States. Currently we have approximately 125 items in our line excluding special versions for specific customers. APT manufactures spring and summer seasonal goods, bulk vehicles, ride-on, girls, role playing and furniture toy categories.



American Plastic Toys Inc.• ASTM Related Topics

– Natural (i.e. unpigmented) polypropylene & polyethylene resins will not contain any of the eight elements at detectable levels.

– We have tested 20 Million pounds of raw resin representing 105 different lots/batches of material over the last 15 months.

– In every case, test results for the 8 ASTM elements in these resins confirmed these plastics are not just compliant, but the element content is so low/non-existent as to be undetectable



• Technical Considerations – Polyethylene and polypropylene are produced from

petroleum or natural gas, which do not contain appreciable amounts of the regulated metals. These gases are polymerized in a reactor in a closed process which eliminates contamination opportunities.

– Resin producers are careful to control the presence of trace metals, as these will interfere with the ability to obtain desired properties in the finished plastic.



Polypropylene & Polyethylene natural Raw resin should be excluded by regulation based on the test data submitted. • We as a manufacturer know what goes into our products.• Excluding PP & PE Resin will produce an annual savings of

$30,000 for APT; this is a significant percentage of our overall testing expenditure.

• Resin manufacturing is a technical and controlled process. Resin is tested and certified throughout the pellet manufacturing process.

• We receive material certificates with each shipment



• Manufacturing Safe, Quality and FUN products is our top priority

• Having quality systems in place throughout our manufacturing process for periodic testing and inspection gives us assurance that our products are compliant.

• Eliminating the need to test materials that do not have detectable levels of the eight elements is a great way to reduce third party testing costs without compromising safety or compliance.

Lead and ASTM F963 Elements: Workshop on Potential Ways To Reduce Third Party Testing Costs Through...

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