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U.S. Consumer Product Safety Commission
Workshop on Potential Ways To Reduce Third
Party Testing Costs Through Determinati...
US CONSUMER PRODUCT SAFETY COMMISSION
Disclaimer
 This presentation was prepared by
CPSC staff, has not been reviewed or ...
LEAD AND ASTM F963-11
ELEMENTS
Moderator: Patricia Adair
4/3/2014 US CONSUMER PRODUCT SAFETY COMMISSION 3
Lead
 Commission determined materials that do not
exceed 100 ppm lead content, and are not subject
to third party testing...
Lead
 For manufactured materials, what specific
information and data should staff assess in
considering a recommendation ...
Lead
 What specific information and data staff should
obtain to be assured that continued production of
a material, regar...
Lead
 What changes would you recommend to improve
the procedures of 16 CFR 1500.89 in furtherance
of the Commission’s spe...
Lead
 What additional lead determinations would provide
the greatest cost savings, assuming that the
determinations have ...
ASTM F963-11 Elements
 A possible determination could identify materials
that do not, and will not, contain the eight
ele...
ASTM F963-11 Elements
 Which materials, by their nature, do not, and will
not contain any of the eight elements in conten...
ASTM F963-11 Elements
 How can compliance with the solubility limits of the
elements other than lead be inferred from con...
ASTM F963-11 Elements
 Which materials would present the greatest cost
reduction if the Commission determined that third
...
Panel Participants
 Nikki Brown, Penn State University
 Bill Perdue, American Home Furnishings Alliance
 Mark Fellin, J...
Hailey Mann – Lead/ASTM Panel
30
• Thank you for the opportunity to participate on this panel.
• I would like to introduce American Plastic Toys, Inc. (APT...
American Plastic Toys CPSC Lead/ASTM Panel 32
Operations:
APT currently has five buildings with over 1,000,000 square feet...
American Plastic Toys CPSC Lead/ASTM Panel 33
American Plastic Toys Inc.
• ASTM Related Topics
– Natural (i.e. unpigmented...
American Plastic Toys CPSC Lead/ASTM
Panel
34
American Plastic Toys Inc.
American Plastic Toys CPSC Lead/ASTM Panel 35
American Plastic Toys Inc.
• Technical Considerations
– Polyethylene and pol...
American Plastic Toys CPSC Lead/ASTM Panel 36
American Plastic Toys Inc.
Polypropylene & Polyethylene natural Raw resin
sh...
American Plastic Toys CPSC Lead/ASTM Panel 37
American Plastic Toys Inc.
• Manufacturing Safe, Quality and FUN products is...
Lead and ASTM F963 Elements: Workshop on Potential Ways To Reduce Third Party Testing Costs Through Determinations Consist...
Lead and ASTM F963 Elements: Workshop on Potential Ways To Reduce Third Party Testing Costs Through Determinations Consist...
Lead and ASTM F963 Elements: Workshop on Potential Ways To Reduce Third Party Testing Costs Through Determinations Consist...
Lead and ASTM F963 Elements: Workshop on Potential Ways To Reduce Third Party Testing Costs Through Determinations Consist...
Lead and ASTM F963 Elements: Workshop on Potential Ways To Reduce Third Party Testing Costs Through Determinations Consist...
Lead and ASTM F963 Elements: Workshop on Potential Ways To Reduce Third Party Testing Costs Through Determinations Consist...
Lead and ASTM F963 Elements: Workshop on Potential Ways To Reduce Third Party Testing Costs Through Determinations Consist...
Lead and ASTM F963 Elements: Workshop on Potential Ways To Reduce Third Party Testing Costs Through Determinations Consist...
Lead and ASTM F963 Elements: Workshop on Potential Ways To Reduce Third Party Testing Costs Through Determinations Consist...
Lead and ASTM F963 Elements: Workshop on Potential Ways To Reduce Third Party Testing Costs Through Determinations Consist...
Lead and ASTM F963 Elements: Workshop on Potential Ways To Reduce Third Party Testing Costs Through Determinations Consist...
Lead and ASTM F963 Elements: Workshop on Potential Ways To Reduce Third Party Testing Costs Through Determinations Consist...
Lead and ASTM F963 Elements: Workshop on Potential Ways To Reduce Third Party Testing Costs Through Determinations Consist...
Lead and ASTM F963 Elements: Workshop on Potential Ways To Reduce Third Party Testing Costs Through Determinations Consist...
Lead and ASTM F963 Elements: Workshop on Potential Ways To Reduce Third Party Testing Costs Through Determinations Consist...
Lead and ASTM F963 Elements: Workshop on Potential Ways To Reduce Third Party Testing Costs Through Determinations Consist...
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Lead and ASTM F963 Elements: Workshop on Potential Ways To Reduce Third Party Testing Costs Through Determinations Consistent With Assuring Compliance

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Determinations for lead and the eight elements in ASTM F963 as a means for third party testing cost reduction: questions, issues, and comments. CPSC staff presentation followed by panelist presentations

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Lead and ASTM F963 Elements: Workshop on Potential Ways To Reduce Third Party Testing Costs Through Determinations Consistent With Assuring Compliance

  1. 1. 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.
  2. 2. 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. 4/3/2014 2
  3. 3. LEAD AND ASTM F963-11 ELEMENTS Moderator: Patricia Adair 4/3/2014 US CONSUMER PRODUCT SAFETY COMMISSION 3
  4. 4. 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 4/3/2014 4US CONSUMER PRODUCT SAFETY COMMISSION
  5. 5. 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? 4/3/2014 US CONSUMER PRODUCT SAFETY COMMISSION 5
  6. 6. 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? 4/3/2014 US CONSUMER PRODUCT SAFETY COMMISSION 6
  7. 7. 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? 4/3/2014 US CONSUMER PRODUCT SAFETY COMMISSION 7
  8. 8. 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? 4/3/2014 US CONSUMER PRODUCT SAFETY COMMISSION 8
  9. 9. 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. 4/3/2014 9US CONSUMER PRODUCT SAFETY COMMISSION
  10. 10. ASTM F963-11 Elements  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)? 4/3/2014 US CONSUMER PRODUCT SAFETY COMMISSION 10
  11. 11. ASTM F963-11 Elements  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? 4/3/2014 US CONSUMER PRODUCT SAFETY COMMISSION 11
  12. 12. ASTM F963-11 Elements  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? 4/3/2014 US CONSUMER PRODUCT SAFETY COMMISSION 12
  13. 13. 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 4/3/2014 US CONSUMER PRODUCT SAFETY COMMISSION 13
  14. 14. Hailey Mann – Lead/ASTM Panel 30
  15. 15. • 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
  16. 16. American Plastic Toys CPSC Lead/ASTM Panel 32 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.
  17. 17. American Plastic Toys CPSC Lead/ASTM Panel 33 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
  18. 18. American Plastic Toys CPSC Lead/ASTM Panel 34 American Plastic Toys Inc.
  19. 19. American Plastic Toys CPSC Lead/ASTM Panel 35 American Plastic Toys Inc. • 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.
  20. 20. American Plastic Toys CPSC Lead/ASTM Panel 36 American Plastic Toys Inc. 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
  21. 21. American Plastic Toys CPSC Lead/ASTM Panel 37 American Plastic Toys Inc. • 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.

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