Phthalate determinations as a means for third party testing cost reduction: questions, issues, and comments. CPSC staff presentation followed by panelist presentations.
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
Staff introduction for CPSC workshop on third party testing cost reduction through possible material determinations. Provides workshop agenda, background, and workshop goals
Overview of testing, certification, and record keeping requirements for consumer products, including children's products. Addresses initial certification testing, material change testing, and periodic testing if you have continued production. Presentation also addresses optional component part testing. A review of mandatory recordkeeping requirements and undue influence training is also discussed.
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
Staff introduction for CPSC workshop on third party testing cost reduction through possible material determinations. Provides workshop agenda, background, and workshop goals
Overview of testing, certification, and record keeping requirements for consumer products, including children's products. Addresses initial certification testing, material change testing, and periodic testing if you have continued production. Presentation also addresses optional component part testing. A review of mandatory recordkeeping requirements and undue influence training is also discussed.
An overview of the federal toy safety standard ASTM F963, some examples, its recent updates, the example of one toy company, and emerging issues and hazards, as presented by a consumer advocacy group. Info current as of September 2013. Safety Academy 2013
2014 updates for durable infant and toddler products. How to locate CPSC data on regulatory non-compliance notices, which are also called "letters of advice" (LOAs). The referenced Excel table will be updated frequently with the names of the firm, the foreign manufacturer, and other information. Businesses may integrate this information into their compliance workflows to assist them in sourcing safe & compliant consumer products.
CPSC experts and representatives of a law firm used this presentation to discuss testing and certification issues, component parts testing, and certificates of conformity.
This panel is especially suited for those attendees who are already familiar with the section 15 reporting obligations and have interacted with Compliance/Field staff on investigations and actual recalls. Includes discussion of priority issues related to being prepared in the event a recall is necessary, working effectively with Field investigators during inspections, how to improve recall effectiveness through the appropriate remedy choice and how to ensure safe adequate disposal of recalled products.
Overview of third party testing rules for children's products, including initial certification testing, material change testing, and periodic testing if you have continued production. Presentation also addresses optional component part testing. A review of mandatory recordkeeping requirements and undue influence training is also discussed. Pairs with video at http://www.youtube.com/watch?v=cR4RXQjmqC8
An international panel comprised of members of AQSIQ (China), INMETRO (Brazil), Health Canada and CPSC (U.S.) used this presentation to discuss the regulatory structure and suggestions for businesses.
The U.S. Consumer Product Safety Commission (CPSC or Commission), an independent federal regulatory agency, is charged with protecting the American public against unreasonable risks of injury and death from consumer products. The CPSC estimates that for the period from 2009 to 2011, an annual average of 6,700 fires, 70 civilian deaths, 680 injuries, and $308.1 million in property loss in residential fires resulted where a candle was reported to be the heat source. This presentation will provide an update on CPSC staff’s work addressing the hazard of residential fires ignited by candles and candle accessories. The presentation will include information on CPSC staff’s participation in developing ASTM voluntary standards for candles, including addressable concerns not included in the current standards, how the CPSC determines whether a product presents a substantial product hazard, and the reporting requirements for manufacturers, retailers, and importers .
Key words: candle, candles, recalls, NASFM, NCA, CP 04-1/HP 04-1, candle fires, root cause analysis, candle accessories, substantial product hazard,
Slides for afternoon discussion session of electronic certificate workshop on a *proposed* amendment to the current certification rule, 16 CFR Part 1110. Slides consist of CPSC staff presentation followed by other federal government participants and non-federal government panelist presentations.
What data can you use to drive your business and improve product design? CPSC has databases you can use to look for product problems by searching through consumer product-related incidents, injuries and deaths to take proactive action and minimize risk. CPSC experts will discuss how these databases are used by CPSC internally to examine potential actions; how to search and use CPSC’s national injury database (NEISS) and SaferProducts.gov to identify problems; and how these databases may benefit business and industry in promoting safer products.
An overview of the federal toy safety standard ASTM F963, some examples, its recent updates, the example of one toy company, and emerging issues and hazards, as presented by a consumer advocacy group. Info current as of September 2013. Safety Academy 2013
2014 updates for durable infant and toddler products. How to locate CPSC data on regulatory non-compliance notices, which are also called "letters of advice" (LOAs). The referenced Excel table will be updated frequently with the names of the firm, the foreign manufacturer, and other information. Businesses may integrate this information into their compliance workflows to assist them in sourcing safe & compliant consumer products.
CPSC experts and representatives of a law firm used this presentation to discuss testing and certification issues, component parts testing, and certificates of conformity.
This panel is especially suited for those attendees who are already familiar with the section 15 reporting obligations and have interacted with Compliance/Field staff on investigations and actual recalls. Includes discussion of priority issues related to being prepared in the event a recall is necessary, working effectively with Field investigators during inspections, how to improve recall effectiveness through the appropriate remedy choice and how to ensure safe adequate disposal of recalled products.
Overview of third party testing rules for children's products, including initial certification testing, material change testing, and periodic testing if you have continued production. Presentation also addresses optional component part testing. A review of mandatory recordkeeping requirements and undue influence training is also discussed. Pairs with video at http://www.youtube.com/watch?v=cR4RXQjmqC8
An international panel comprised of members of AQSIQ (China), INMETRO (Brazil), Health Canada and CPSC (U.S.) used this presentation to discuss the regulatory structure and suggestions for businesses.
The U.S. Consumer Product Safety Commission (CPSC or Commission), an independent federal regulatory agency, is charged with protecting the American public against unreasonable risks of injury and death from consumer products. The CPSC estimates that for the period from 2009 to 2011, an annual average of 6,700 fires, 70 civilian deaths, 680 injuries, and $308.1 million in property loss in residential fires resulted where a candle was reported to be the heat source. This presentation will provide an update on CPSC staff’s work addressing the hazard of residential fires ignited by candles and candle accessories. The presentation will include information on CPSC staff’s participation in developing ASTM voluntary standards for candles, including addressable concerns not included in the current standards, how the CPSC determines whether a product presents a substantial product hazard, and the reporting requirements for manufacturers, retailers, and importers .
Key words: candle, candles, recalls, NASFM, NCA, CP 04-1/HP 04-1, candle fires, root cause analysis, candle accessories, substantial product hazard,
Slides for afternoon discussion session of electronic certificate workshop on a *proposed* amendment to the current certification rule, 16 CFR Part 1110. Slides consist of CPSC staff presentation followed by other federal government participants and non-federal government panelist presentations.
What data can you use to drive your business and improve product design? CPSC has databases you can use to look for product problems by searching through consumer product-related incidents, injuries and deaths to take proactive action and minimize risk. CPSC experts will discuss how these databases are used by CPSC internally to examine potential actions; how to search and use CPSC’s national injury database (NEISS) and SaferProducts.gov to identify problems; and how these databases may benefit business and industry in promoting safer products.
Jim Helmkamp, Senior Epidemiologist for the National Institute for Occupational Safety and Health Western States Office, presented this at CPSC's ATV Safety Summit Oct. 12, 2012. State-specific ATV fatality rates were compared between 1990-1999 and 2000-2007 grouping states according to helmet, and training and licensure requirements (per SVIA state ATV requirement charts). 2,226 deaths occurred from 1990-1999 at a rate of 0.09 deaths per 100,000 population and 7,231 deaths from 2000-2007 at a rate of 0.32. Male rates were at least six times higher than female rates. Males accounted for about 86% of the deaths overall. Children under 17 years accounted for over one-third of the deaths in the earlier period decreasing to about 17% in the latter. The number of deaths increased 225% from the earlier period to the latter with a three-fold increase in the death rate. There was little collective difference between rates for states with or without helmet requirements and between states with or without training and licensure requirements. Policy-oriented prevention strategies over the past decade seem to have largely failed. This failure may be due to lack of enforcement and the casual attitude of many ATV riders to not wear a helmet or take training.
An overview of the CPSC PGA message set, electronic filing alpha pilot, and certificate registry with walkthrough of example filing and detailed information on proposed timeline
This presentation on fire reduction strategies for residential furniture details the role of flame retardants and compares usage and analysis in various jurisdictions.
Cam Arnold, Vice-President of the Right Rider Access Fund, presented this at CPSC’s ATV Safety Summit Oct. 11, 2012. The Right Rider Access Fund sponsored "Do the Ride Thing", an ATV and dirt bike safety video contest, in collaboration with the ATV Safety Institute and the Motorcycle Safety Foundation. "Do the Ride Thing" enhances young riders' knowledge of the "Golden Rules" of ATV safety while empowering them to communicate safety messages to their peers through their own PSA video. The contest, in its third year, ran from June 1 to August 15, 2012 and offered 19 prizes totaling $8,500. Students ages six to 18 could enter. Creating a safety video that highlights one or more of ASI's "Golden Rules" is a great way to motivate and inform the public - especially kids and their parents - about the safe and responsible use of all-terrain vehicles. The contest harnesses the social networking power of YouTube and it gives kids the opportunity to "Do the Ride Thing" and help other kids ride safe/ride smart.
Dr. Charles Jennissen, of the University of Iowa Department of Emergency Medicine presented this at CPSC's ATV Safety Summit Oct. 12, 2012. The study objective was to determine the ATV anticipatory guidance practices of primary care providers, as well as their attitudes, knowledge, and the barriers faced in educating families about the risk of ATV use. Methods: An electronic survey was administered to primary care providers belonging to Iowa state medical societies. Results: More than 60% of respondents (N=218) believed that providing ATV anticipatory guidance was important. However, 78% gave ATV safety counseling less than 10% of the time during regular pediatric exams, and only 12% did so greater than 25% of the time. Families rarely ask providers for advice on ATV safety issues; 84% of providers were asked once a year or less. ATV knowledge scores were low (median score 2 of 12); however, those with previous ATV exposure had significantly higher scores. Many respondents affirmed insufficient knowledge (47%) and inadequate resources (63%), but the most commonly identified barrier was that it was not a routine part of their practice.
Webinar on greener water and oil repellents in the textile industry: Occupati...OECD Environment
On 30 October 2018, Eeva Leinala of the OECD Environment Directorate; Ruth Garcia, Gemma Janer and Marc Torrentellé from LEITAT Technological Center; and Julio Fierro of the Centro Tecnológico de Investigación Multisectorial (CETIM) presented the MIDWOR-LIFE project that aims to mitigate the environmental, health and safety impacts of current Durable Water and Oil Repellents and available alternatives by looking at their environmental impact and technical performance.
Material Data Safety Sheet Page 1 of 5
AvantTM Eco-Premium Instant Hand Sanitizer Product Number: 21000
SECTION 1 – PRODUCT AND COMPANY IDENTIFICATION
Product Name AvantTM Eco-Premium Instant Effective Date 03/01/12
Hand Sanitizer
Transportation Emergency (24 Hour) Contact
Company B4 Brands INFOTRAC
1001 North Washington Street North America: 1-800-535-5053
Lisbon, IA 52253 USA Outside North America: +1-352-323-3500
Phone Number Product Information Medical Emergencies: Contact your local
1-888- 667-6066/ www.b4brands.com poison control center.
HMIS Rating Health 2 Transportation
Flammability 3 DOT: CONSUMER COMMODITY, ORM-D
Physical Hazard 0 IATA: CONSUMER COMMODITY, ID8000, Class 9
IMDG: UN1170, ETHANOL SOLUTION, Class 3, LTD QTY
SECTION 2 – HAZARDS IDENTIFICATION
Emergency Overview
This material is an Over-The-Counter consumer product that is safe for consumers with intended and reasonable
foreseeable use.
Hazard Classification: Flammable Liquid, Cat. 3 Signal Word(s): Warning Hazard Symbol(s):
Hazard Statement: Flammable liquid and vapour
Precautionary Statements:
FLAMMABLE. Keep away from fire or flame.
Do not use in eyes. In case of eye contact, flush thoroughly with water and seek medical attention.
Stop use and ask doctor if irritation and redness develop and persists for more than 72 hours.
Keep out of reach of children. If swallowed, get medical help or contact a Poison Control Center right away.
SECTION 3 – COMPOSITION / INFORMATION ON INGREDIENTS
Ingredients considered hazardous as defined by OSHA, 29 CFR 1910.1200, WHMIS under the HPA (Canada),
or ESIS (Europe).
Chemical Name CAS Number EINECS/ELINCS Wt % OSHA PEL ACGIH TLV
Ethyl Alcohol 64-17-5 200-578-6 70-75 TWA 1000ppm TWO 1000ppm
Isopropanol 67-63-0 <5 400 ppm 200 ppm
Remaining ingredients are non-hazardous and/or present at amounts below reportable limits and considered confidential.
SECTION 4 – FIRST AID MEASURES
Eye Contact Immediately flush the eye(s) with water for at least 15 minutes while holding eyelids open.
Seek medical attention in the event of an adverse reaction or if symptoms of irritation worsen.
Skin Contact In case of irritation, immediately wash affected area with soap and water. Seek medical
attention in the event of an adverse reaction or if symptoms of irritation worsen.
Ingestion Seek medical attention if ingestion occurs.
Material Data Safety Sheet Page 2 of 5
AvantTM Eco-Premium Instant Hand Sanitizer Product Number: 21000
Inhalation Product is not likely to be hazardous by inhalation. If respiratory irritation or distress occurs,
remove victim to fresh air and seek medical attention.
SECTION 5 – FIRE FIGHTING MEASURES
...
EU GMP Annex 1 – Implications on Filtration and Single Use Technology by Soma...MilliporeSigma
What are the major drivers for the new Annex 1? Join us to know more about implications for Filters & Single Use.
In this webinar, you will learn:
• Closed Processing and Single Use Technology implementation
• Points to consider using Single Use Technology
• Sterile Filtration
The Annex 1 “Manufacture of sterile medicinal products” of the EU GMP Guide is currently being revised. A first draft of the revised version was published in 2017 and released for public comment. The second draft as of February 2020 was open for targeted consultation via stakeholder from selected industry organisations. The current Annex 1 draft emphasises Contamination Control Strategy (CCS) multiple times and as a key consideration.
EU GMP Annex 1 – Implications on Filtration and Single Use Technology by Soma...Merck Life Sciences
What are the major drivers for the new Annex 1? Join us to know more about implications for Filters & Single Use.
In this webinar, you will learn:
• Closed Processing and Single Use Technology implementation
• Points to consider using Single Use Technology
• Sterile Filtration
The Annex 1 “Manufacture of sterile medicinal products” of the EU GMP Guide is currently being revised. A first draft of the revised version was published in 2017 and released for public comment. The second draft as of February 2020 was open for targeted consultation via stakeholder from selected industry organisations. The current Annex 1 draft emphasises Contamination Control Strategy (CCS) multiple times and as a key consideration.
Animal testing safety endpoints in chemical industryMIHIR PUJARA
This presentation describes animal testing safety end points in chemical industry according to REACH(registration,evaluation,authorisation & restriction of chemicals).
REACH was established to control manufacturing and importing of chemicals in EU market & to minimize the risks to human health and environment.
this presentation mainly based on the regulatory aspects of packaging and gives all significance about packaging regulations,help in pharma or biotechnology .
Customer Bulletin 0410 A Comparison of ISO-C1 and HT-300Joe Hughes
This Customer Bulletin is part of a series of white papers aimed at providing our clients, engineers, contractors, fabricators, and friends with objective information on competitive products. Marketing literature on the internet and in printed media address the physical and performance characteristics of competing polyisocyanurate rigid foam insulations fabricated from bunstock. As is often the case, some literature can be misleading and/or in some cases there may not be sufficient information to credibly compare products. This Customer Bulletin provides factual, clarifying information which should allow for an objective comparison of Dyplast’s ISO-C1® with HiTherm’s HT-300 (each 2 lb/ft3 density).
Customer Bulletin 0515 A Comparison of ISO ISO-C1 and HT-300Dyplast Products
PURPOSE
This Customer Bulletin is part of a series of white papers aimed at providing our clients, engineers, contractors, fabricators, and friends with objective information on competitive products. Marketing literature on the internet and in printed media address the physical and performance characteristics of competing polyisocyanurate rigid foam insulations fabricated from bunstock. As is often the case, some literature can be misleading and/or in some cases there may not be sufficient information to credibly compare products. This Customer Bulletin provides factual, clarifying information which should allow for an objective comparison of Dyplast’s ISO-C1® with HiTherm’s HT-300 (each 2 lb/ft3 density).
Customer Bulletin 05-15 A Comparison of ISO-C1 and HT-300 Polyisocyanurate In...Joe Hughes
This Customer Bulletin is part of a series of white papers aimed at providing our clients, engineers, contractors, fabricators, and friends with objective information on competitive products. Marketing literature on the internet and in printed media address the physical and performance characteristics of competing polyisocyanurate rigid foam insulations fabricated from bunstock. As is often the case, some literature can be misleading and/or in some cases there may not be sufficient information to credibly compare products. This Customer Bulletin provides factual, clarifying information which should allow for an objective comparison of Dyplast’s ISO-C1® with HiTherm’s HT-300 (each 2 lb/ft3 density).
Light stabilizer uv 3853pp5 cas 167078-06-0 msds, Our products are organic pigments, antioxidants, uv absorber, light stabilizers, optical brighteners. Also are agent of Addivant and Xrite in China, website:https://www.additivesforpolymer.com email:info@additivesforpolymer.com
Webinar on greener water and oil repellents in the textile industry: Recommen...OECD Environment
On 30 October 2018, Eeva Leinala of the OECD Environment Directorate; Ruth Garcia, Gemma Janer and Marc Torrentellé from LEITAT Technological Center; and Julio Fierro of the Centro Tecnológico de Investigación Multisectorial (CETIM) presented the MIDWOR-LIFE project that aims to mitigate the environmental, health and safety impacts of current Durable Water and Oil Repellents and available alternatives by looking at their environmental impact and technical performance.
Similar to Phthalates: Workshop on Potential Ways To Reduce Third Party Testing Costs Through Determinations Consistent With Assuring Compliance (20)
A briefing for the Consumer Product Safety Commission by CPSC staff from the Directorate for Engineering Sciences, Division of Mechanical Combustion Engineering.
Regulatory cooperation should be relevant and responsive to real world challenges. This panel provides perspectives on new trends, products, and hazards and what can be done within the North America Cooperation framework. Points of focus: Cooperation and best practices, Policy Alignment, Consumer messaging.
Presenters: Agustin Adame, Consultant; Belinda May, ICPHSO President and Partner, Dentons US LLP; Carol Pollack-nelson, Ph.D. Independent Safety Consulting; Gene Rider, Eponent, Principal.
Hazards associated with high energy density batteries are common to all three jurisdictions. How can risk to consumers be reduced and what steps have already been taken by stakeholders in North America? Points of focus: 1. Industry's product safety processes pre- and post-market. 2. Understanding and eliminating failure modes. Challenges and how can stakeholders and regulators work together to improve safety?
Presenters: Charlie Monahan, Director, Regulatory Compliance, Panasonic; Don Mays, Chief Safety and Quality Officer, Samsung; Rick Brenner, President, Product Safety Advisors, LLC.
Stakeholders and regulators discuss the benefits and challenges posed by the rapid expansion of e-commerce. Discussion of industry processes and best practices. How can regulators help platforms help their sellers and consumers?
Presenters: Doug Hyland, Compliance Program Manager, zulily; Stuart Schmidt, Manager, Trade Compliance, UPS; Carlos Ponce Beltran, Deputy Attorney for Telecommunications, PROFECO.
Presentation by Blake G. Rose, Director, Defect Investigations Division Office of Compliance and Field Operations on CPSC Review of Recall Process and Standard Notifications.
Presentation Date: July 25, 2017
Building Your Employer Brand with Social MediaLuanWise
Presented at The Global HR Summit, 6th June 2024
In this keynote, Luan Wise will provide invaluable insights to elevate your employer brand on social media platforms including LinkedIn, Facebook, Instagram, X (formerly Twitter) and TikTok. You'll learn how compelling content can authentically showcase your company culture, values, and employee experiences to support your talent acquisition and retention objectives. Additionally, you'll understand the power of employee advocacy to amplify reach and engagement – helping to position your organization as an employer of choice in today's competitive talent landscape.
Part 2 Deep Dive: Navigating the 2024 Slowdownjeffkluth1
Introduction
The global retail industry has weathered numerous storms, with the financial crisis of 2008 serving as a poignant reminder of the sector's resilience and adaptability. However, as we navigate the complex landscape of 2024, retailers face a unique set of challenges that demand innovative strategies and a fundamental shift in mindset. This white paper contrasts the impact of the 2008 recession on the retail sector with the current headwinds retailers are grappling with, while offering a comprehensive roadmap for success in this new paradigm.
Industrial Tech SW: Category Renewal and CreationChristian Dahlen
Every industrial revolution has created a new set of categories and a new set of players.
Multiple new technologies have emerged, but Samsara and C3.ai are only two companies which have gone public so far.
Manufacturing startups constitute the largest pipeline share of unicorns and IPO candidates in the SF Bay Area, and software startups dominate in Germany.
At Techbox Square, in Singapore, we're not just creative web designers and developers, we're the driving force behind your brand identity. Contact us today.
Best practices for project execution and deliveryCLIVE MINCHIN
A select set of project management best practices to keep your project on-track, on-cost and aligned to scope. Many firms have don't have the necessary skills, diligence, methods and oversight of their projects; this leads to slippage, higher costs and longer timeframes. Often firms have a history of projects that simply failed to move the needle. These best practices will help your firm avoid these pitfalls but they require fortitude to apply.
Taurus Zodiac Sign: Unveiling the Traits, Dates, and Horoscope Insights of th...my Pandit
Dive into the steadfast world of the Taurus Zodiac Sign. Discover the grounded, stable, and logical nature of Taurus individuals, and explore their key personality traits, important dates, and horoscope insights. Learn how the determination and patience of the Taurus sign make them the rock-steady achievers and anchors of the zodiac.
Digital Transformation and IT Strategy Toolkit and TemplatesAurelien Domont, MBA
This Digital Transformation and IT Strategy Toolkit was created by ex-McKinsey, Deloitte and BCG Management Consultants, after more than 5,000 hours of work. It is considered the world's best & most comprehensive Digital Transformation and IT Strategy Toolkit. It includes all the Frameworks, Best Practices & Templates required to successfully undertake the Digital Transformation of your organization and define a robust IT Strategy.
Editable Toolkit to help you reuse our content: 700 Powerpoint slides | 35 Excel sheets | 84 minutes of Video training
This PowerPoint presentation is only a small preview of our Toolkits. For more details, visit www.domontconsulting.com
FIA officials brutally tortured innocent and snatched 200 Bitcoins of worth 4...jamalseoexpert1978
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Implicitly or explicitly all competing businesses employ a strategy to select a mix
of marketing resources. Formulating such competitive strategies fundamentally
involves recognizing relationships between elements of the marketing mix (e.g.,
price and product quality), as well as assessing competitive and market conditions
(i.e., industry structure in the language of economics).
In the Adani-Hindenburg case, what is SEBI investigating.pptxAdani case
Adani SEBI investigation revealed that the latter had sought information from five foreign jurisdictions concerning the holdings of the firm’s foreign portfolio investors (FPIs) in relation to the alleged violations of the MPS Regulations. Nevertheless, the economic interest of the twelve FPIs based in tax haven jurisdictions still needs to be determined. The Adani Group firms classed these FPIs as public shareholders. According to Hindenburg, FPIs were used to get around regulatory standards.
Company Valuation webinar series - Tuesday, 4 June 2024FelixPerez547899
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Navigating the world of forex trading can be challenging, especially for beginners. To help you make an informed decision, we have comprehensively compared the best forex brokers in India for 2024. This article, reviewed by Top Forex Brokers Review, will cover featured award winners, the best forex brokers, featured offers, the best copy trading platforms, the best forex brokers for beginners, the best MetaTrader brokers, and recently updated reviews. We will focus on FP Markets, Black Bull, EightCap, IC Markets, and Octa.
Recruiting in the Digital Age: A Social Media MasterclassLuanWise
In this masterclass, presented at the Global HR Summit on 5th June 2024, Luan Wise explored the essential features of social media platforms that support talent acquisition, including LinkedIn, Facebook, Instagram, X (formerly Twitter) and TikTok.
Recruiting in the Digital Age: A Social Media Masterclass
Phthalates: Workshop on Potential Ways To Reduce Third Party Testing Costs Through Determinations Consistent With Assuring Compliance
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. 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
4. Phthalates
A possible determination could identify materials
that do not, and will not, contain prohibited
phthalates in concentrations above 0.1 percent
4/3/2014 4US CONSUMER PRODUCT SAFETY COMMISSION
5. Phthalates
What specific data should staff consider when
deciding whether to recommend that the
Commission make a determination?
How can staff be assured that a material,
regardless of its origin, manufacturing process,
potential for contamination or any other factor,
would continue to comply with the phthalates limit
indefinitely into the future as the material
continues to be produced?
4/3/2014 US CONSUMER PRODUCT SAFETY COMMISSION 5
6. Phthalates
What kind of follow-up activities should be required
to assure continued compliance of a material?
What other technical, practical, or implementation
issues should CPSC staff consider before possibly
making recommendations to the Commission
regarding phthalates determinations?
What materials would provide the greatest cost
savings if the Commission made a determination
that the material did not contain the prohibited
phthalates above 0.1 percent? Why?
4/3/2014 US CONSUMER PRODUCT SAFETY COMMISSION 6
7. 2009 Statement of Policy:*
Materials that may contain phthalates
Polyvinyl chloride (PVC) and related polymers, such as
polyvinylidene chloride (PVDC), and polyvinyl acetate (PVA);
Soft or flexible plastics, except polyolefins;
Soft or flexible rubber, except silicone rubber and natural
latex;
Foam rubber or foam plastic, such as polyurethane (PU);
Surface coatings, non-slip coatings, finishes, decals, and
printed designs;
Elastic materials on apparel, such as sleepwear;
Adhesives and sealants;
Electrical insulation; and
Other materials: other plastics, inks, air fresheners, and
scented products.
4/3/2014 US CONSUMER PRODUCT SAFETY COMMISSION 7
*http://www.cpsc.gov//PageFiles/126588/componenttestingpolicy.pdf
8. Materials that may contain phthalates
What materials should always require third party
testing because of potential phthalate content above
0.1 percent? Why?
What specific data or other information should be
sufficient to characterize a material as potentially
containing one or more of the prohibited phthalates,
and thus, always require third party testing for
compliance to the phthalates limit?
4/3/2014 US CONSUMER PRODUCT SAFETY COMMISSION 8
9. CPSC Phthalates Symposium, March 1, 2012
Failure Rate by Self-Declared Material (Intertek)
4/3/2014 US CONSUMER PRODUCT SAFETY COMMISSION 9
*Bob Altkorn, Intertek, presentation, ―Phthalates Screening and Testing Methods,‖ 3/1/2012,
http://www.cpsc.gov/Media/Documents/Regulations-Laws--Standards/CPSIA/Same-Symposium-Different-Links-Temp/altkorn03012012/
10. Conforming Plastics
What raw materials are used, could be used, or may
be used to create plastics that meet these
requirements, as well as information about the
possibility of those materials containing or being
exposed to any prohibited phthalate?
Information about the potential use of recycled content
in these plastics, and the possibility that phthalates
may be included at noncompliant levels?
4/3/2014 US CONSUMER PRODUCT SAFETY COMMISSION 10
11. Conforming Plastics
Information about the possibility or likelihood of
contamination of the component part or finished
product with a prohibited phthalate?
How or why continued manufacture, regardless of
origin, would continue to be compliant with the
phthalates limit?
4/3/2014 US CONSUMER PRODUCT SAFETY COMMISSION 11
12. Conforming Plastics
How the Commission might effectively address
new applications or methods of production of
plastics that may include the addition of phthalates
or otherwise result in unacceptable levels of
phthalates?
What other technical, practical, or implementation
issues should CPSC staff consider before possibly
making recommendations to the Commission
regarding a phthalates determination for a plastic?
4/3/2014 US CONSUMER PRODUCT SAFETY COMMISSION 12
13. Conforming Plastics
What would be the potential cost savings if such a
determination were recommended and adopted,
especially considering that compliance with the
underlying standard(s) would still be required?
4/3/2014 US CONSUMER PRODUCT SAFETY COMMISSION 13
14. Panel Participants
Dave Owens, BASF
Sanjeev Gandhi, SGS Consumer Testing Services
Alan Kaufman, Toy Industry Association
Sheila Millar, Keller and Heckman, LLP
Kyra Mumbauer, Society of the Plastics Industry
4/3/2014 US CONSUMER PRODUCT SAFETY COMMISSION 14
16. CPSIA Law
CONSUMER PRODUCT SAFETY IMPROVEMENT ACT OF
2008
PUBLIC LAW 110–314—AUG. 14, 2008
Sec. 101 Lead
Sec. 102 Mandatory third party testing
Sec. 108 Prohibition on sale of certain products containing
specified phthalates
16
17. CPSIA Law
Children’s toy that can be placed in a child’s mouth
Child care article
sucked and chewed
smaller than 5 centimeters in one dimension
17
19. CPSIA Law
concentrations of more than 0.1 percent
Each phthalate can be present at 0.1%
PERMANENT PROHIBITION
DBP
BBP
DOP
INTERIM PROHIBITION
DnOP
DINP
DIDP
19
20. Phthalates
FDA approved for food contact
Closures
Wraps
Used in medical applications
Blood bags
Tubing
20
24. Physical Properties
Density
– ~1
Viscosity
– Less than 100 centipoise
Pour Point
– ~ -40
Flash Point
– > 200 C
Vapor Pressure
– ~ 6 millibar @ 200 C
24
27. Typically Not For
Olefins
– Compatibility
Stryrenics
– Stress Cracking
Nylon
– Can use water
Rigid PVC
– Antiplasticization
27
28. Theory
Cohesive Energy Density/Solubility Parameter
Gibbs Free Energy
The Technology of Plasticizers Sears & Darby
Handbook of Plasticizers Wypych
28
29. Thanks
BASF Corporation
Uwe Storzum
Kathy Stahl
Kristi Utecht
ANA
ASTM Task Group Members
THIS PRESENTATION IS INTENDED AS GENERAL INFORMATION OF CURRENT INTEREST AND IS NOT INTENDED AS LEGAL
ADVICE. BASF CORPORATION (BASF) MAKES NO WARRANTY OR REPRESENTATION, EITHER EXPRESS OR IMPLIED, WITH
RESPECT TO THE ACCURACY OR COMPLETENESS OF THE INFORMATION CONTAINED HEREIN, AND ASSUMES NO LIABILITY OF
ANY KIND WHATSOEVER RESULTING FROM THE USE OF OR RELIANCE UPON ANY INFORMATION, PROCEDURES, CONCLUSION,
OPINION OR RESULTS OBTAINED.
29
30. CPSC Workshop
Potential Ways to Reduce Third Party
Testing
CPSC National Product Testing and Evaluation Center
Rockville, Maryland
April 03, 2014
Sanjeev Gandhi
DVP and Technical Director
SGS North America, Inc.
31. 31
Workshop Goals
Identify what material specific exemptions can be
determined to reduce testing based validation
Phthalates, Lead, and 8 Soluble HMs
Consider
Intrinsic material characteristics
Manufacturing, processing, downstream use
Compliance should not be compromised
Provide tangible saving in testing cost
32. 32
Phthalates
Phthalates: Suspect list exists vinyl and vinyl like
soft plastics
Create a Positive List for exempt plastics/materials
Plastics commonly
used in consumer
applications*
PE 33 %
PP 21 %
PS 8 %
PVC17 %
ABS< 10%
* Plastics Europe: MRG Report
Other Plastics: Not common for consumer
products
POM automotive and consumer electronics
PBT electrical housings, automotive plugs,
showerheads
PC electronics, construction, aerospace
PLA medical implants, biodegradable
PPS electrical insulation, specialty
membranes
33. 33
A look at the empirical data....
Test data for phthalates
10, 400 data points
Plastics data represents 60 -70 of the total data points
The bill of materials is not provided
34. 34
Testing Lab perspective ....
Lab data for phthalates
Data is not granular to provide specific polymers that can be
considered categorically for exemption
Across all the plastic and rubber like materials, high
compliance rate with the limits, approx 95%
The difference in fail and positive detection (above DL) ≈
1000 data points (for plastics and rubber)
This alludes to possible contamination issue
Mixing of polymers intended or otherwise
35. 35
Phthalates
Technical/Practical considerations determination of a
positive list
Bill of materials from upstream supplier: guarantee letter
Exemption based on material properties that change pure
polymers with addition of plasticizer
– Shore hardness known potential issues
– Glass transition temperature not fully examined in scientific
literature
36. Opportunities to Reduce
Third Party Testing Costs
for the Plastics Industry
Consumer Product Safety Commission
April 3, 2014
37. Founded in 1937, SPI is the only U.S. trade association
representing all segments of the plastics industry.
38. MISCONCEPTION: All plastic materials used in
children’s products must be tested to ensure
compliance with phthalate limits.
REALITY:
• The restricted ortho-phthalate plasticizers may be intentionally added to flexible
polyvinyl chloride, polyvinylidene chloride, chlorinated polyvinyl chloride and
thermoset polyurethanes to make these materials flexible.
• The restricted ortho-phthalate plasticizers will NOT be added to rigid plastic
materials (Shore “A” Hardness ≥ 90), nor will they be present in these materials as
contaminants at levels higher than 1000ppm.
• The restricted ortho-phthalates are incompatible with many plastic materials (e.g.,
styrenics, polyolefins), and these materials are made flexible by other means.
May contain phthalates > 1000ppm Will not contain phthalates > 1000ppm
41. MISCONCEPTION: Cross-contamination may lead to
the unintentional presence of phthalates in excess of
1000ppm in a variety of plastic products.
REALITY: Manufacturers have strong incentives to avoid
cross-contamination of rigid plastics with phthalates or with flexible PVC
that may contain phthalates.
Destruction of resin
Off-gassing from
chemical reaction
Corrosion of
equipment
Facility
evacuation
Poor technical performance
42. SPI’s Recommendation
to Reduce Testing Costs
SPI respectfully requests that the Commission:
• Specify that rigid plastic materials with Shore “A” Hardness
of 90 or greater will not contain the restricted phthalates
in excess of specified limits.
• Publicly identify the many types of plastic materials that
are known not to contain the restricted phthalates in
excess of specified limits.
43. Thank you!
Kyra Mumbauer
Senior Director, Global Regulatory
Affairs
SPI: The Plastics Industry Trade
Association
O: 202-974-5214
C: 202-427-4472
kmumbauer@plasticsindustry.org
44.
45.
46.
47.
48.
49.
50.
51.
52.
53.
54.
55.
56.
57.
58.
59.
60.
61.
62. U.S. Consumer Product Safety Commission
Workshop on Potential Ways to Reduce Third-Party Testing Costs
Through Determinations Consistent With Assuring Compliance
Sheila A. Millar, Partner
KELLER AND HECKMAN LLP
1001 G Street, N.W.
Suite 500 West
Washington, D.C. 20001
+1 202.434.4143
millar@khlaw.com
April 3, 2014
63. Who Is FJATA?
We make and sell jewelry.
• About 225 companies
• Mostly small businesses
• Led drafting of
Children’s Jewelry
Standard (ASTM
F2923-11) and Adult
Jewelry Standard
(ASTM F2999-13)
• Leading process to
update both standards
64. Phthalates Testing Requirements &
the Marketplace
• Jewelry items are not toys
• The distribution chain has
begun imposing testing
requirements that match
CPSC’s, even for products
that do not require such
testing
• Testing is a significant added
burden for jewelry items
• Component testing
multiplies test costs
65. Rigid Plastics Will Not
Contain Phthalates
• When phthalates are
present, they are added
intentionally in amounts
far about the trace
levels that CPSIA bans
• The limited available
data from FJATA
member tests shows
phthalates either not
present or present in
levels under 25% of the
maximum in tested rigid
plastics
66. CPSC Rule Needed to
Eliminate Unnecessary Test Costs
• Rigid plastics – materials with a Shore ―A‖ Hardness rating 90
or above - will not contain phthalates.
• In fact, most plastics will not contain phthalates
• Technical data supports, with a high degree of
assurance, that these materials will not contain
phthalates and CPSC should issue a rule
recognizing exclusions from phthalates testing
67. Thank you!
Sheila A. Millar, Partner
KELLER AND HECKMAN LLP
1001 G Street, N.W.
Suite 500 West
Washington, D.C. 20001
+1 202.434.4143
millar@khlaw.com
April 3, 2014