3. Objective
• Inform about lead testing requirements
• Proof of compliance
• Search for information
4. Background
• Measures are being taken to control the metal content of
products (Lead, cadmium, barium, mercury, arsenic or
antimony) in products primarily for use by children 12yrs of
age and under(jewelry, toys etc)
• Metal content of adult jewelry or any ornament worn on the
body that a child can have possession of(including watches,
watch bands, cell charms, hair accessories, zipper pulls
Enforcement means
Laws ( Consumer Product Safety Commission)
Procurement requirements
5. Why conduct a lead test on products
• Avoid Health related problems with
product handling (skin diseases, poisoning etc)
• Build confidence in customers/customer
retention high
• Opportunity to grow customer base/market as
a result of good reputation with safety of products
• Increased revenue with increased sales
• Generation of income with increased job opportunities
6. Fundamentals of the lead content regulations
• Bans unsafe levels of lead in jewelry etc
• Requires both importers and exporters to show proof of a
laboratory test by an internationally recognized and certified
body
• Establishes penalties and
consequences for ignoring or
violating the law
7. What constitutes non-compliance of lead test
rules
• To be negligent of lead content of source of dye or paint used
for products for export
• Refusal to do a lead test of products for export
• Export products without testing for lead
• Export products without a test certificate accompanying
products
8. Consumer Product Safety
The Consumer Product Safety Commission
(CPSC) has created mandatory limits on
proportions of lead and certain
phthalates in products intended primarily
for use by children 12 years of age and
below.
Lead in paint of products(whether designed
for children or not) has a limit of 90 parts
per million (ppm)
Children’s metal jewelry (understanding that
all metal jewelry can fall into this
category whether for children or not has
a limit of 300ppm
9. Compliance procedures
• Search for information (internet)
• Be vigilant and ask appropriate and relevant questions
• Know the source of your dye, paint or surface coating
• Be conversant with the procedures for the testing of lead
• Have a certified laboratory test
10. Role of the importer/buyer
• Make due diligence to ascertain
the source of supply of the dye,
paint, coat surfacing etc
• Ensure that shipments are accompanied by a lead-safe certification
to enter the country of importation, US etc. Make sure the
laboratory test is certified by the recognized body.
• May request for samples of jewelry or children’s items in advance
to determine the toxicity of products before shipping. Some buyers
have invested in X-ray fluoroscope to test their products and will be
will to share data from this equipment with suppliers.
11. Exporter
• Suppliers will have to provide importers with clear
information on their source of dye, paint, surface coating
• Suppliers will need to update their records with constantly
changing policies of toxic material content on products
exported (of the importers or buyers)
• Assist buyers/importers with
relevant documentation or
certification to facilitate the
smooth passage of custom
procedures.
12. Caution
• Be weary of your supply source of dye, paint or surface
coating
• Make the customer your focus.
Customers are becoming more and
more health conscious and aware of
environmentally friendly chemicals
and products and will go an extra mile
to make further investigations or enquiries on products
• Producers may loose or attract customers depending on the
evidence they provide on the safe or hazardous nature of
their products
13. Caution………
• Don’t be carried away by paper indication like “lead free”
• Don’t be ignorant about the existing standards for toxic
material content ( e.g. State, Federal and CPSC laws) of the
destination countries of your products
14. Available testing laboratories
Internationally recognised laboratories for lead testing include;
Societe Generale de Surveillance (SGS) – www.sgs.com
With laboratories in Ghana, Cote d’Ivoire, France,
Bureau Veritas (BV)- www.bureauveritas.sn
With laboratories in Tunisie, Côte d'Ivoire, Morroco, South
Africa, Spain and France.
Laboratoire de controle de qualite Bio-Connex
Analytique(LBCA)- Accrédité ISO 17025:2005,
www.labobioconnex.com
With a laboratory in Cote d’Ivoire
15. Areas for discussion and clarification with
laboratories
• 1. SAMPLING:
The client is responsible for preparing representative samples
to a suitable scale ( quantity and volume to be discussed with
the laboratory of choice). Samples could be collected by the
laboratory courier at the address provided by the client and
this could attract some charges.
• 2. SAMPLE ANALYSIS:
All laboratory analyses will be conducted
according to standard methods for dried
paint samples, including surface coatings.
16. Continue……….
• 3. DOCUMENTATION:
Solid samples must be firmly wrapped in polyethylene sleeves
or bags kept firmly closed by adhesive tape. For liquid samples
glass bottles equipped with a plastic safeguard must be used
to prevent breaks or losses while travelling. ( Confirm with the
laboratory of your choice)
• For any information regarding sampling, conservation and
shipping of samples, please contact key departments usually
provided on the websites.
17. Continue…
• Laboratory requests that
samples submitted for analysis
be accompanied with a
Sample Submission Sheet.
This remains the official communication regarding the required
sample analysis. Please make sure that all relevant details are
provided on the Sample Submission Sheet. The information
could include written instructions indicating:
Client name & address including phone and fax numbers, for reports to be sent to;
Purchase order number;
Contact person's name and phone number should questions arise regarding project;
Sample identification and analysis (methods if required) to be done including laboratory’s
quote reference if applicable.
18. Continue…
• 4. QUALITY CONTROL:
The client can inquire about a full
time QA/QC specialist on site
responsible for all quality control
aspects of the operation as well as
the maintenance of the quality
system which accords with ISO
guide 17025.
19. Continue…….
• 5. TURNAROUND TIME:
Most laboratories state a turnaround time of 10 working
days.
• 6. ANALYTICAL COST PER SAMPLE:
Usually a specific quotation in US$
20. Continue……
• 7. TERMS OF PAYMENT AND CONDITIONS OF SERVICE:
Agree on a favourable terms of payment with the service
provider
Most laboratories have Conditions of Service which apply
and must be signed by the client (please read and
understand before signing)
Payment is usually in US Dollar and strictly after a stated
number days of date of invoice. A breach of this could lead
to services being suspended for defaulting clients.
21. Penalties/Consequences
• Exporters stand the risk of having their shipment seized upon
arrival by customs officials if not accompanied by the a
certified laboratory test
• Goods may also be destroyed by the customs of the
destination country
• Buyers will continue to reject or return any item or shipment
that does not pass State or Federal standards for toxic
material content
• Suppliers or exporters will loose clients and potential clients
resulting in loss of market for one’s products
• Ultimately, it is money invested gone down the drain
22. Thank You
Learn more about the USAID West Africa Trade Hub project at
www.watradehub.com
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