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J C Sprowls



Joined: 25 Mar 2006
Posts: 2004

PostPosted: Tue Dec 09, 2008 12:26 pm    Post subject: Reply with quote

Still, the costs of implementing and maintaining an XRF solution is much more capital intensive than testing. While it might be a partial solution, it's insufficient at this time.

We need to avoid rabbit holes and continue to apply ourselves to a solution that makes sense and is scalable up to the big guys and down to the little guys.
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Kathleen F.
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Joined: 08 Sep 2005
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Location: NM Albuquerque

PostPosted: Tue Dec 09, 2008 12:28 pm    Post subject: Reply with quote

dd wrote:
Xrf will likely be approved in the future for certified lead in substrate testing, and yes, it does tell you ppm. Actually if you go on cpsia and watch the xrf videos, they claim that in many instances, xrf gives a more accurate picture then other methods.

The point is, it's not approved now. We're not dealing with what ifs when what's now is so bad.

Quote:
Believe me, I am not an xrf salesperson. I am just trying to look at possibilities.

Possibilities don't help us at this point and we don't know who you are. Altho a large forum with 900 members, we're used to addressing people by name and knowing something about them. In that vein, if you care to introduce yourself, you can do that [url=//fashion-incubator.com/phpbb/viewtopic.php?t=3399]here[/url].
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blizzard77
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PostPosted: Tue Dec 09, 2008 12:52 pm    Post subject: Reply with quote

And for those of us who do not wholesale, xrf or another general certification of conformity IS a possible (albeit temporary)solution. Is it a long-term solution, one that would benefit those that wholesale to larger stores/chains or a possibility for those who manufacturer higher-risk goods? No. But it buys the rest of us some time. And that time would be well-used to lobby for exemptions, ammendments and clarification.
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J C Sprowls



Joined: 25 Mar 2006
Posts: 2004

PostPosted: Tue Dec 09, 2008 1:01 pm    Post subject: Reply with quote

You just insist on staying in that rabbit hole, don't you?

If you want the XRF solution to be considered, then I recommend you raise that to the legislators for consideration. As it stands, it is not a certified test.

Can I ask that we stop quoting entire posts? It just consumes bandwidth and makes reading that much more difficult. If you're responding to a specific statement, the quote feature is helpful so other readers have context.

If you just want to give somebody a high five or a pat on the back, please use the PM feature. Doing it in posts adds un-necessary length and makes the posts more difficult to read.
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Kathleen F.
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PostPosted: Tue Dec 09, 2008 1:14 pm    Post subject: Reply with quote

Quote:
Can I ask that we stop quoting entire posts? ... the quote feature is helpful so other readers have context.... please use the PM feature.

J- I haven't seen long quoting or rather, didn't notice (she squeaks). Please don't hesitate to PM me the links to given posts and I'll edit. I should assign some moderators. Volunteers please PM me. Members might want to check out [url=//fashion-incubator.com/phpbb/viewtopic.php?p=19773#19773]this thread[/url].

Guests don't have access to the PM feature.
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Pamela
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PostPosted: Tue Dec 09, 2008 2:03 pm    Post subject: Reply with quote

I just had a customer call me to tell me how much she loved our clothing and she was telling all her friends. Just a few days ago this type of call made my day, gave me a great feeling. Today it didn't. However, I did take the time to tell her what we were running into as a small manufacturer of children's clothing. I told her how she could help by sending a letter to her congressman too. This is the type of thing we need to do and get the public, consumer making some noise about it too.

Pam
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Jennifer T.
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PostPosted: Tue Dec 09, 2008 4:42 pm    Post subject: XRF Testing - Clarification Reply with quote

Kathleen - I'm not sure I understand your confusion between what I wrote on my blog and what I posted here. The CPSIA provides that as of 2/10/09 you can't sell children's products with more than 600 ppm lead. But the law does NOT require third party testing as of that date - the third party testing will be required for children's products in 8/09 for the 300 ppm standard (because the CPSC is required to publish the notice by 5/16/09, and the third party testing rule cannot be effective until 90 days after the notice is published).

Is that a distinction without a difference? Not really. Retailers may decide to require 3rd party testing to satisfy their needs. But they do not have to do so. The CPSC's FAQ points to one option - use XRF. XRF can be used to test existing inventory and to issue general conformity statements (required from manufacturers/importers) until 8/16/09. XRF is approved for this purpose by CPSC.

And to those concerned about lawsuits, XRF is used by most agencies - CPSC, DTSC, etc. - and is acceptable.

Finally, I'm just one person, there are others, but I charge $100 per hour in person - can test between 10 and 25 items per hour - or $5 per item by mail.
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Jennifer T.
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PostPosted: Tue Dec 09, 2008 4:47 pm    Post subject: XRF - and PPM Reply with quote

Esther - XRF Analyzers do tell you the ppm. The analyzers will give total lead in ppm, down to 1 ppm. When I test, I issue a certificate indicating the testing procedure, time, calibration, and results for all elements tested and it is signed.

The XRF analyzer is registered with the state of Cal., but it is not part of the approved laboratory accreditation under the CPSC. As DD says, those procedures have not even been issued for lead in children's products, only lead paint.
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Jennifer T.
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PostPosted: Tue Dec 09, 2008 4:53 pm    Post subject: XRF more Reply with quote

Sorry for the multiple posts - I keep seeing stuff in the thread that deserves a response.

I think XRF is an option for the time being - to buy some time until a fix is done. I've already accepted one project from a small manufacturer - she is sending me her samples and I'm testing them as part of her reasonable testing program. It will probably be $200 - $300 dollars for her - not a big investment for some piece of mind. If we get anything close to 600 ppm, she'll send it out to a lab for further testing. Seems like a workable solution.

And I've tested all the toys at another importer as part of his general conformity certificated reasonable testing program.

Both of these are recommended under the CPSC's FAQ for this purpose.

Jennifer
www.thesmartmama.com
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Esther
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PostPosted: Tue Dec 09, 2008 5:04 pm    Post subject: Reply with quote

I am sorry, I don't get the XRF gun. Are you a certified 3rd party lab? If not, then it becomes a cost-benefit ratio. In any event, some things have to be 3rd party tested now, others in the timeline over the next 8 months. And since the testing must be done by SKU......
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Jennifer T.
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PostPosted: Tue Dec 09, 2008 5:41 pm    Post subject: XRF - Interim Solution Reply with quote

Esther - The XRF analyzer is an interim solution. The children's products lead limits come into effect 2/10/09. At that point, inventory will have to be verified and manufactured products will need a general conformity statement. The 3rd party testing requirement under the CPSIA is NOT effective until 8/16/09.

So, the XRF can be used to test inventory & newly manufactured products. For inventory, it can allow you to sell products without worrying that they are banned hazardous substances. (This does not apply to lead paint - lead paint must have a 3rd party certificate.)

For newly manufactured, the XRF can satisfy a 'reasonable testing program' as required by the CPSC for the general conformity statement.

It is a cheaper solution than laboratory analysis or throwing away the inventory. It gives an interim option until the 3rd party testing requirements are effective on 8/16/09 - and by then, I hope that there is a fix to address these issues.
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Esther
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PostPosted: Tue Dec 09, 2008 6:57 pm    Post subject: Reply with quote

Not to belabor the point but 3rd Party testing is required for certain things now (jewelry, cribs, pacifiers are just some). Why bother testing one thing officially, and not others. Waste of time and money when the deadlines are so short.

The CPSC needs to make their timetable more clear. Adds so much to the confusion. That is why I would recommend to just go ahead with the official, CERTIFIED testing if you are going to bother with it all.
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heartlanddreams
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PostPosted: Tue Dec 09, 2008 9:21 pm    Post subject: Reply with quote

Forgive me if I'm a little slow, but from what I'm reading, for my product (cloth diapers made by me and sold directly to a consumer, no retailer involved), is it correct that as of Feb 10, I *may* be able to use supplier certifications for a time as a "reasonable testing process"?

I realize this isn't a long term solution, but it may buy some time for me to be able to stay in business and figure out how to make the rest of it work.

Tina
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annika
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PostPosted: Wed Dec 10, 2008 9:00 am    Post subject: Reply with quote

"Reasonable" isn't really defined in the CPSC docs, but if you can get copies of test results from your suppliers that seems very reasonable to me. However, currently it won't be acceptable as of August 2009. But that gives you time to figure something out, or hopefully amendments will be made.
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Kathleen F.
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PostPosted: Wed Dec 10, 2008 9:52 am    Post subject: Reply with quote

Hopefully I've made sufficient clarifications in [url=//fashion-incubator.com/archive/cpsia-and-small-manufacturers/]today's entry[/url]?
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