CPSIA Lead Laws

I am printing a copy of an article published in Textile World Magazine pertaining to the new CPSIA regulations.
CPSC Issues Policy Paper On Lead Content In Children’s Products
James A. Morrissey, Washington Correspondent
The Consumer Product Safety Commission (CPSC) has issued a new policy statement covering the lead content in products used by children. The policy appears to exempt virtually all fabric, both dyed and undyed, from testing and certification requirements. The Consumer Product Safety Improvement Act requires that products intended for use by children under 12 years of age may not contain more than 300 parts per million of lead. Products that exceed that level are required to be tested by third-party labs and certified as to their lead content. In its announcement, CPSC said: "The law limits our ability to exempt products from the lead content limit, however, we have found that certain products, by their nature, will never exceed the lead content limit, so those products do not need to be tested and do not need certification to show that they comply with the law." CPSC says textile fabric falls into the exempt category, but the exemption may not apply to after-treatments such as screen printing, transfers, decals or other printing`. With respect to final products that may contain a number of components, including some exempt and non-exempt, the commission said it will address that question in a later rulemaking. October 27, 2009

This is good news on the apparel manufacturing front, but leaves the burden of compliance in the use of snaps, screen prints, embroidery patches, zippers, etc. Let's discuss this a bit.

It is now a given that the textile componant will pose no lead hazard. How about a snap or snap tape? New "low lead" snaps are on the market, and the cost of these products is 50-85% MORE than the standard product. Lead is a necessary evil in the manufacture of snaps. so even the "low lead" units have some lead content, but are below the boundary of 300ppm. Now, has anyone tested how much lead would come out of an unpainted nickle based snap if sucked on for 100 hours? How many snaps would be required to be in an infants mouth, and for how long, before any lead would leach out into their system? Is there an ASTM "suck test"? Would they need to eat the snaps? Wouldn't the consumption of snaps fall under some other safety regulation regarding sharp objects or removable objects? How about screen printing? Sure, plastisol printing can be abraded by teeth and possibly be consumed in small quantities, so maybe, if indeed there is lead in plastisol ink, it makes sense. What about water based digital prints or discharge prints? I suppose the ASTM "suck tester" would be needed again, but we are speaking of ink. Do we need a lead test on every piece of paper with printing on it that may come in contact with an infant? What about that digital print on the cute little phenol free bottle he has? What about the printed bumber pad and pillows in his crib? His sheets or pillows likely have zippers!

I am not against safety regulations, but if we are going to regulate than we had best be sure that the consequences of these regulations are not onerous and do not cause a litigatory creative rigamortise so that anyone trying to enter the industry is scared silly. In the meantime we are using "low lead" snaps, and the costs are having to both be absorbed or passed on.