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Finding CPSC testing labs
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J C Sprowls

Joined: 25 Mar 2006
Posts: 2004

PostPosted: Wed Nov 12, 2008 5:50 pm    Post subject: Reply with quote

Most mills do test their fabrics because they need to deliver to spec, too. This is why I said you can typically get a copy of the test results from the fabric agent just by asking sweetly. But... you can't always trust this information. Doing a couple simple, inexpensive tests is a good way to validate the results.

That said... the CPSC has not decided if you - the manufacturer of the finished product - can defer accountability to the test results performed upstream. This is what I mean about the $15M hot potato. If you were asked to put $15M on the line, would you trust anyone's results other than the ones you supervised?
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PostPosted: Wed Nov 12, 2008 6:23 pm    Post subject: Reply with quote

Thanks JC. I missed part of what you said earlier and I only buy fabric from a jobber, so I was worried about getting the information.

But I talked to him today and he only buys his satin from one or two places and told me he could get whatever information I need.

I have no idea about what tests I can do to validate the results, but I am going to search on that. (If anyone has any links that I may have missed, please let me know.)

Then on to the lead issue....
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Kathleen F.
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Joined: 08 Sep 2005
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PostPosted: Thu Nov 13, 2008 10:44 am    Post subject: Reply with quote

SarahM wrote:
Think about this...in theory, shouldn't the fabric manufacturers be testing their goods before we buy them????

Sure. And retailers can say the same to us (considering only a tiny percentage of the manufacturers out there even bother with shrink testing, color fastness or durability much less testing for toxins) and then consumers can say the same to retailers. Obviously it makes sense to start at the top of the supply chain but the legislation isn't and CAN'T be structured this way due to myriad international sources. Playing devil's advocate, is it possible for international suppliers to bullet proof their goods as it pertains to the legislation of all nations who may end up (or not) buying goods for use in their nations? Who's going to enforce it? Just try getting that one through GATT. And then what about states within states (ex: how many things are banned in CA as opposed to other states).

Obviously one should only buy from those international sources who've chosen to voluntarily comply with our laws but will they? If they do, they may lose market share from buyers from nations without those restrictions because those goods will be more expensive.
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Joined: 17 Mar 2006
Posts: 1917
Location: ID Spudville

PostPosted: Thu Nov 13, 2008 12:18 pm    Post subject: Reply with quote

This is a problem the CPSC needs to address. If a supplier does their testing and is in compliance with certain standards, should a manufacturer be forced to re-test to confirm. If each step of the supply chain is required to test, it leads to duplicate testing - a truly inefficient and wasteful system IMO.

The certificates of conformity are essentially rendered useless if each step of the supply chain must do all of their own testing.
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Kathleen F.
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PostPosted: Mon Dec 22, 2008 6:03 pm    Post subject: Reply with quote

Can't find a better place to put this. Rob Wilson (cpsia central) sent me a very intriguing email.

I just got off the phone with a testing lab that said they would allow batch testing (ie. we have 2 items made from the same components---they would test the same colored components once). I questioned if this is allowed, based on what I had heard. He said it has been left up to the labs. He couldn't go on record, but will put me in touch with someone that could, and could provide back-up.

Additionally, he said that testing frequency would typically be once per year, unless suppliers changed. Again, he said it is up to the lab. Again, he will get me details shortly.

Does this sound correct to you? It would be a breakthrough of sorts if it is accurate. Still, I hate to be held hostage by the whims of the testing labs...rather that it is clearly stated in the law.

I responded with:
Kathleen F. wrote:
REALLY!? Wow! Boy, that would be awesome for a lot of small producers. Put it this way, if they were careful about the items they selected, they could conceivably cover the gamut of their products with two or maybe three items. Do keep me posted on what you come up with. Hopefully we can get it in writing? sounds hopeful, thanks!

-and we need all the good news we can get.

Then Rob wrote back with this confirmation:
Rob Wilson wrote:
This what I got back from NSF Testing. I am not certain if this is what the CPSC had in mind, but it is what NSF is interpreting to mean like materials can be batch tested. They provided a quote 2 items on the same quote.

NSF Lab wrote:
> It was a pleasure speaking with you today. I have attached a CPSIA FAQ document. On page 3 they address compositing materials for testing. It is acceptable on like materials and paint, but very clearly not acceptable on differing materials. The quote reads as follows:

Q: Is compositing allowed for testing for lead in the surface paint/coating or in the substrates (that is the underlying materials that are painted or coated)?

A: The term “compositing” could refer to more than one type of combination. One type of compositing that labs have used is to combine like paint from several like parts or products to obtain a sufficient sample size for analysis where there is not sufficient quantity of paint on one item to perform the testing. This is appropriate in this circumstance and may even be necessary to obtain valid analytical results.

Another type of compositing is to combine different paints or substrates from one or more samples to reduce the number of tests run. This type of composite testing may fail to detect excessive levels of lead in one individual paint or substrate because they have been diluted. This approach is therefore not acceptable.

In other words, it seems it may be possible to aggregate your testing if you are careful to select items with inputs that are representative of your full range of products. This could prove to be very good news!
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PostPosted: Mon Dec 22, 2008 6:10 pm    Post subject: Reply with quote

Major labs will currently do this for testing and certifying to other standards (like some EU standards). We submit three baby carrier in three colorways, but identical otherwise. They test each fabrication/colorway combination, then test the webbing only once, the buckles only once, the batting only once, etc. So there is certainly a precedence for this.

You'd just have to be organized and submit all of your samples together.

Of course, I'd rather see component testing, but this is better than nothing!
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PostPosted: Thu Jan 01, 2009 2:23 pm    Post subject: Reply with quote

Hi All,

Maybe I'm confused. Confused
I was thinking of getting a quote fron NSF testing but I just looked at the "approved" list of testing labs
and they weren't on it.

So that certification would only be good until August or they are approved but not on that link somehow?

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