Staff introduction for CPSC workshop on third party testing cost reduction through possible material determinations. Provides workshop agenda, background, and workshop goals

1. U.S. Consumer Product Safety Commission
Workshop on Potential Ways To Reduce Third
Party Testing Costs Through Determinations
Consistent With Assuring Compliance
April 3, 2014
This presentation was prepared by CPSC staff, has not been reviewed or approved
by, and may not reflect the views of, the Commission.

2. US CONSUMER PRODUCT SAFETY COMMISSION
Disclaimer
 This presentation was prepared by
CPSC staff, has not been reviewed or approved
by, and may not reflect the views of, the
Commission.
 The views and opinions expressed by public
participants during this workshop are those of the
participants and do not represent official
government policies or positions of the
Commission or its staff.
 This workshop is being webcast and recorded.
Please identify yourself when speaking.
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3. CPSC Staff Workshop Agenda
 9:00 Introductory Remarks
 9:15 Purpose, Scope, & Goals
 9:45 Phthalates
 11:45 Lunch Break
 1:15 Lead and ASTM 8 Elements
 3:00 Break
 3:15 Discussion
 4:00 Closing Remarks
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4. Workshop Purpose
 Additional research
• Scientifically defensible
• Widest scope of relief
• Not affect safety and compliance of children’s
products
 Possible rulemaking on expanding the list
of materials eligible for determinations
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5. Workshop Scope
 Scope is limited to research in support of
possible determinations rulemaking. Not
included in the workshop are:
• Certification issues;
• Test methods;
• Statutory content limits;
• Definitions; and
• Other matters not related to determinations.
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6. Consumer Product Safety Improvement
Act of 2008 (CPSIA)
 Limits lead content in substrate for accessible
component parts of children’s products to
100 ppm
 Limits content of six phthalates for children’s
toys and child care articles to 0.1 percent
 Mandatory toy safety standard
(ASTM F 963-11) limits soluble amounts of
eight elements: antimony, arsenic, barium,
cadmium, chromium, lead, mercury, and
selenium
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7. Compliance Testing
 Children’s products that are subject to a
CPSC children’s product safety rule must
be tested by a third party CPSC-accepted
laboratory (Section 14(a)(2) of the CPSA).
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8. Burden Reduction
 Public Law 112–28 (August 12, 2011)
directed CPSC to seek comment on
‘‘opportunities to reduce the cost of third
party testing requirements consistent
with assuring compliance with any
applicable consumer product safety rule,
ban, standard, or regulation.’’
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9. Previous Commission Actions
 Request for Comment (RFC): Application of
Third Party Testing Requirements; Reducing
Third Party Testing Burdens
• 76 FR 69596; 11/8/11; Staff briefing package;
8/29/12
 Request for Information Regarding Third
Party Testing for Lead Content, Phthalate
Content, and the Solubility of the Eight
Elements Listed in ASTM F963–11
• 78 FR 22518; 4/16/13
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10. CPSC Staff Workshop
 79 FR 11088; February 27, 2014
 www.regulations.gov
• CPSC Docket No. CPSC–2011–0081
 Written comments submitted by April 17,
2014
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11. CPSC Staff Workshop Goals
 Information and evidence about possible
determinations that certain materials comply with
the applicable content or solubility limits of
applicable children’s product safety rules with a
high degree of assurance
• Irrespective of their manufacturing origin or
manufacturing process
• Without requiring third party testing
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12. CPSC Staff Workshop Goals
 Information about factors relevant to
demonstrating a high degree of assurance of
compliance to the applicable children’s product
safety rules
• Consideration of raw material sourcing
• Manufacturing processes used
• Possible presence of recycled materials
• Potential for contamination
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13. CPSC Staff Workshop Topics
 Three areas for possible determinations
• Phthalate content
• Lead content
• Solubility of the eight elements in the toy standard
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