I know, I know. Boring technical jargon. It’s all true.
But unless you have someone else in your company to take care of this for you, you can’t afford not to know how to read a test report.
There’s an easy way and a hard way. I’ll show you the easy way. The hard way is to find out that the product you thought was compliant isn’t compliant and that the official looking test report you’ve got in your file is out of date, not relevant to your specific product or doesn’t include all the tests you need.
I know. I learned the hard way.
Back in 2007, when the testing mania began and before we started ordering our own tests, we asked all of our factories to send us test reports for the products in our line. This was a year before CPSIA, before phthalate limits, before lead-in-substrate limits, and before mandatory ASTM F963. The only federal lead restriction was the 600 ppm limit for lead in paint or surface coating—the one that tripped up Mattel with their Barbie Doll recalls.
We received plenty of official looking reports and most of them from well-known testing labs. They referred to tests and codes like EN71, RoHS and 16 CFR 1303. Some included photographs, some did not. We dutifully filed them away and provided them on request to any distributor who asked—the ones doing business with corporations who have really knowledgable compliance people. And that’s when the education began—when those people saw the holes in some of the reports we provided.
“This report is dated 2005. Do you have a current one?” “The product in this report is a tumbler but it doesn’t look anything like one than we’re buying.” “EN71 is for Europe. Do you have a test report for the US standard ASTM F963?”
You get the idea. Almost none of the reports were for the actual products in our line. Most were outdated and covered mostly European standards.
Bullet point one: If the test isn’t for the exact product you’re purchasing, it doesn’t mean anything. Never mind that the factory says it’s made of the same material. If you’re purchasing Prime’s LT-3290 then the test report needs to say LT-3290. And it should have a picture so you know for sure that the test is for the same product you’re ordering.
Bullet point two: The test should be current. The date is critical because the standards have changed. It doesn’t help you to have a lead test dated April 2011 if the bag you’re buying was manufactured in September. The lead standard in April was 300 ppm. After August 14 it changed to 100 ppm.
Speaking of ppm, that’s just a way of expressing a very dilute concentration of a substance. It means one out of a million the way percent means one of a hundred. So lead of 90 ppm means 90 parts out of a million. Bullet point three: Since the number is critical, make sure the test report shows the actual number—not just PASS or FAIL. Without that number you can’t tell if the product complies with the current standards in the law. In CPSIA particularly the lead standards have been continually phased down since August 2008.
Bullet point four: Don’t assume that the test covers everything. Last year we received a passing test report for a small battery powered stuffed toy. The test passed but the battery compartment wasn’t included in the sample tested. After 5,000 pieces were produced we learned that the battery compartment didn’t comply and required several thousand dollars of rework. Expensive mistake.
Labs only perform the tests that they’re asked to perform, just as in the stuffed toy example. So if you see a report with a passing lead test, look closely to see what it is covering. CPSIA requires two different lead tests. The first is for lead in the material itself – sometimes called total lead or lead-in-substrate. (The actual wording in CPSIA is “total lead content by weight for any part of the product.”) That limit is currently 100 ppm for children’s products. The second requirement is for lead in any paint or surface coating. That could either be a painted surface of the product itself or the imprint/applique that the supplier or decorator applies. Normally ink used for printed material like books and catalogs is considered part of the material. But heat transfers, pad printing and silk screening inks—particularly if they can be scraped off—are usually considered surface coating. The lead limit for paint and surface coating is 90 ppm. So you need a test for the lead in the material and a separate test for lead in any surface coating. The lead in material test is usually labeled on a test report as something like “CPSIA Lead in substrate.” The lead in surface coating test is usually labeled 16 CFR 1303 for the section number of the Code of Federal Regulations (CFR) containing the regulation.
Bullet point five: European standards are for Europe. US standards are for the US. They aren’t the same. If you see a passing test report for EN71—the European toy safety standard—don’t assume that the product will pass ASTM F963—the US toy safety standard. They’re different.
Bullet point six: If your product happens to be a toy, it needs to comply with the the Federal Toy Safety Standard usually referred to as ASTM F963. This used to be a voluntary standard but in CPSIA—the Consumer Product Safety Improvement Act—Congress made it mandatory. ASTM F963 isn’t one test—it’s 67 pages of various tests for which toys need to comply. If you drop the toy from three feet will it shatter? Is it a choke hazard? Does it have sharp edges? Lots of things like that. So if your product is a toy, be sure that the report states that it is fully compliant with all applicable tests from the current ASTM F963 standard. Most labs will do that automatically but remember our battery compartment experience.
Bullet point seven: Toys (and child care items) need to be tested for six phthalates: DEHP, DBP, and BBP, DINP, DIDP, and DnOP. These are plasticizers—chemicals added to make plastic more flexible like the strand that attaches the ear buds to your iPod. The maximum limit for each of these phthalates is .1 percent. Make sure the test report lists all six and indicates that there is no more than .1 percent of each one.
These are the basics for the tests required by CPSIA. There are certainly plenty of other possible tests if your product is subject to another Federal Act, ban or regulation. And there are state regulations too. But let’s save those for a future article.
Remember these seven bullets and you’re 90% of the way there.
