TheSmartMama – CPSIA Solutions – XRF Testing for Lead Content CPSIA Compliance

Okay, so this is a service pitch.  Just skip it if you are not in the market for lead content testing. 

As you know, the Consumer Product Safety Improvement Act (CPSIA) of 2008 set mandatory lead content standards for all children’s products sold or distributed for sale in the United States, among other requirements. While the testing and certification requirements are stayed, you still cannot distribute in commerce any children’s product, or any part of a children’s product, that exceeds 600 parts per million (ppm) lead. That level drops to 300 ppm. 

Trying to figure out whether your products comply?  TheSmartMama provides x-ray fluorescence (XRF) screenings for lead content to support certification claims for CPSIA compliance.  I can provide handheld XRF screenings in my facility (you mail the product) or onsite at your location – whether it be your sales showroom, your warehouse or your store.   

XRF testing is non destructive and is relatively quick.  Components identified with levels of lead potentially of concern can be further tested for lead content, or can be replaced.  The XRF testing is recognized by the CPSC for lead content testing.  Please note that lead in metal children’s jewelry and lead in paints and coatings must be tested using 3rd party accredited testing.  Also, XRF screening cannot identify phthalates.

XRF Testing Services for CPSIA Compliance

Updated May 17, 2009 

TheSmartMama offers XRF testing services for lead content for compliance with the Consumer Product Safety Improvement Act (CPSIA). 

I offer the services by mail and in person. The cost is $5 per test or $100 per hour. Generally, hourly rate is more cost effective. I photograph the product to be tested, and prepare a report with the photograph and the XRF test results by product part. I provide the calibration information for quality control on the XRF test report. This test report can be used for the general conformity certificate (GCC). 

Generally, the manufacturer (or importer) prepares the GCC because there may be requirements in addition to the lead content. Remember, the GCC is supposed to certify the product for all applicable regulations. So, for example, all clothing is supposed to make the flammability requirements. Virtually all clothing, with the exception of children’s sleepwear, meets this requirement BY THE EXEMPTION for weight of fabric – that’s why you never worry about it. The GCC should reflect both the lead content certification and the certification for weight of fabric exemption for flammability. 

Because of the stay of testing and certification, you still do NOT need to do third party accredited testing for most children’s products. Yes, third party testing is required for lead in paints and coatings manufactured after December 22, 2008. Yes, third party testing is required for lead in metal children’s jewelry manufactured after March 23, 2009. But, for most children’s products, lead content testing can be performed using XRF technology, at least until the stay expires on February 10, 2009. 

What is XRF Analysis? 

I use a Niton XRF analyzer.  X-ray fluorescence basically involves exciting the electrons in elements and reading the characteristic energy emitted.  The Niton XRF analyzer can read lead, cadmium, chromium, etc. 

XRF and the CPSIA 

XRF testing can be used to comply with certain provisions of the Consumer Product Safety Improvement Act (CPSIA).  Specifically, XRF can be used to determine whether existing inventory is compliant with the lead content limit for children’s products.  The Consumer Product Safety Commision (CPSC) has explicity stated that XRF can be used as the basis for a reasonable testing program for lead content in children’s products.