Thursday, January 19, 2012

CPSC Standards for Toys- The GCC, ASTM, CPSC, and about 40 other new acronyms to learn

I posted earlier this week on the new enforcement of the CPCS laws regarding toy safety. Well- since I do manufacture toys for children under 12 I must comply with the law and I've registered through the CPSC as a small batch toys manufacturer. I think all Etsy sellers should fall into that category (meaning all that sell toys- being small batch- not that all sellers must register)- if they don't qualify as small batch then they aren't really selling under the spirit of Etsy. You have to make fewer than 7,500 of each item and your sales must be less than a cool $1M (no problem Uncle Sam!)
Registering for a username and password took a day- then on the tail end of the menu bar once you log in you can register for a registration number as a small batch manufacturer. They only took about a half-day to come back with it. That gives you a "Small Batch Manufacturer Registration Number". This number is used in a "certificate of compliance" for covered products.


What are covered products? Here is a link to the regulated products and unregulated products. Regulated Products generally include all of the stuff that kids could put in their mouth. Paints and things must be tested by you or (as a small batch person) you can use a testing certificate from the supplier or other party that has conducted testing on that product. You need to include this testing number in your general certificate of compliance. Items that are generally free of paint (good for me) and free of coatings are not required to be tested. (Yay!) I've also found that the "CPSC has determined that natural wood is by its nature free of lead and heavy metals in levels that might present health concerns.  As a result, the CPSC has exempted natural wood (unpainted wood) from third-party testing. This is good news for my maple teethers (no testing necessary).  All wood products are still subject to mechanical hazards testing which is fine and actually not regulated until there is an issue! The CPSC is generally reactive- meaning that nothing happens until a report or hazard is found. Regardless- I do test my teethers and baby products in accordance with ASTM Standards regarding chipping, splintering, and part sizes. I sand my pieces down to prevent hard edges as well as splinters. I use only hard maple which naturally won't splinter or come apart.The puzzles and games are coated with a CAB acrylic lacquer that has been tested and found to be free from lead content- so I can use the manufacturer data on that one.


Now how to compile and show compliance? And how in the heck do I come up with a General Certificate of Conformance? I'll find out-- and let you know.

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