So, the American Industrial Hygiene Association (AIHA) has written a letter to the editor in response to the USA Today article featuring me and other bloggers. When I got the Google alert with my name, and the brief summary, my heart started pounding. I was thinking what the heck could the AIHA say about me in response to that article? I was actually scared.
Okay, and then I read it. And, I have to say, it is a tad annoying.
The AIHA letter to the editor tackles the appropriate use of the XRF analyzer for regulatory purposes. But that wasn’t even discussed in the USA Today article. And, what is even more annoying is that the letter to the editor gives the mistaken impression that you can’t use the XRF analyzer and get acceptable results, which isn’t true.
So, let me respond. And, let me just disclose (before I get some comments that I’m shilling) that I don’t work for the manufacturer of the device.
I’ll give the AIHA this. It is true that you cannot use the XRF analyzer to satisfy the requirements of the Consumer Product Safety Improvement Act (CPSIA) for children’s metal jewelry manufactured after March 23, 2009. Children’s metal jewelry manufactured after March 23, 2009 must tested by an accredited third party laboratory, and the testing that is required is a digestive testing method (Test Method CPSC-CH-E1001-08 or 2005 CPSC Laboratory SOP).
However, it is incorrect to state that the XRF analyzer cannot be used to screen children’s metal jewelry manufactured before that date for compliance with the children’s product lead content standard. Of course, the operator must recognize the limitations of the equipment. And, there may be sample preparation requirements and adjustments for substrate.
But don’t let the AIHA fool you. The CPSC, as well as a host of other agencies, such as the California Department of Toxic Substances Control (DTSC), use XRF analyzers to screen products in the field. In fact, the CPSC and the DTSC both use XRF to screen metal children’s jewelry to evaluate pieces for further testing. You can’t beat the XRF analyzer for a portable, non destructive way of screening products.
And, the CPSC has approved the use of XRF technology in certain circumstances. No doubt, the CPSC approvses the use of XRF on homogenous plastics. The CPSC recognizes that using XRF for paints and coatings may be acceptable if suitable analytical methods and standards are developed.
The AIHA letter to the editor overlooks (or intentionally omits) the approval that the US Environmental Protection Agency has given to the use of XRF in the characterization of contaminated sites, and the approval that the US EPA and the US Department of Housing and Urban Development have given for XRF in dealing with lead based paint hazards.
Just my two cents.