Melissa & Doug Folding Princess Castle – Review and Giveaway

Well, it is that time of year. I don’t know about your kids, but my kids are asking for everything for Christmas that they see advertised. And almost all of them are plastic and commercially branded. Not particularly inspiring for imaginative play and not particularly earth friendly.

So, when I was approached to do a review of the Melissa and Doug Folding Princess Castle, I was thrilled. (So, yes, I was sent a free castle and doll set for review in the interest of full disclosure.) My daughter has been asking for a pink plastic Barbie castle, and I much preferred non-branded wood. So I accepted. The castle arrived, and it is PERFECT. My princess loves the painted pink accents and the castle’s flexibility. It includes two removable turrets, flying buttresses, and a working drawbridge.

My daughter loves it, and plays with it almost every night. At Thanksgiving, some of my daughter’s cousins joined us, and they were just as entranced with the Folding Princess Castle. Melissa and Doug also generously sent my the Royal Family Wooden Doll Set to review. The girls, my daughter included, love these as well. You should check out all of the Melissa and Doug Toy Castles.

The drawbacks – the drawbridge is a little difficult for my 5 year old doll to manipulate because it is stiff. And, my daughter thinks the painted features on the female royal family members is “too clown like.” Also, just expressed regret that the clothes cannot be removed from the royal family. 

From an environmental perspective, I do like that the castle and dolls are all wood. And, in my XRF testing experience, I haven’t had any lead or cadmium show up for Melissa and Doug Toys. I also love that the toys aren’t branded – I can escape the Disney Princesses or Barbie or any of the others for a little bit.

My daughter is so pleased with the castle, I’ve purchased for her the Princess Castle Furniture set to add to the castle for Christmas. You can check out all of the Melissa and Doug Toy Castles and accessories.

Now, bonus for my readers. I get to give away a Folding Princess Castle or Folding Medieval Castle (value $99 each – you get to pick ONE). It will be a random draw from comments. In the interest of trying (though no promises) to make this for Xmas, the contest is open until 11:59 pm on December 14, 2010. Leave a comment below with which you would prefer if you won. Winner to be notified by email.

If you want a bonus entry, follow Melissa and Doug on Twitter and let me know that you did or already do in a separate comment.

The Sigh Heard Across America: CPSC Gives Relief from CPSIA Lead Content Requirements

Yesterday, August 6, the Consumer Product Safety Commission (CPSC) issued a new regulation that exempts various materials from the lead content limits for children’s products in the Consumer Product Safety Improvement Act (CPSIA).

And a sigh of relief was heard across the United States, and I’m sure across China too.

The CPSIA grants the CPSC the authority to determine that certain materials or products or classes of materials or products do not, and by their nature will not, exceed the CPSIA’s lead content limits. By doing so, the CPSC has relieved the products or materials from the CPSIA’s testing and certification requirements.

However, there is a caveat. If the product or material is changed such that it exceeds the lead limits, then the exemption doesn’t apply. And the CPSC says that it will test materials in the marketplace to make sure. The rulemaking states:

 

Moreover, even when a particular product or material has been relieved of the testing and certification requirements under section 102 of the CPSIA, manufacturers and importers remain responsible for verifying that the material or product has not been altered or modified, or experienced any change in the processing, facility or supplier conditions that could impart lead into the material or product to ensure that it meets the statutory lead levels at all times

As a result, while the exemptions for these materials are wonderful and a lot of companies will feel relief, I have some reservations about wholesale abandonment of testing. (Okay, and I realize that perhaps that sounds self-serving since I perform testing.) The reason I’m concerned is because a manufacturer still needs to comply with the law, and many manufacturers don’t have the type of knowledge needed about supplier conditions and processes. Fabrics will not fail 99.9% of the time. But, some fabrics can fail. I say this having just tested fabrics (which are exempt) for three different companies in the last 3 weeks and having fabric failures. I had a fleece type fabric test at 400 ppm lead; a handful of synthetic felts test at 500 to 1,200 ppm lead; and some heavy woven fabrics out of South America test at 900 to 1,400 ppm lead.

Keep in mind that the new rule, 16 CFR 1500.91(c) provides:

A determination by the Commission under paragraph (b) of this section that a material or product does not contain lead levels that exceed 600 ppm, 300 ppm, or 100 ppm, as applicable, does not relieve the material or product from complying with the applicable lead limit as provided under paragraph(a) ofthis section if the product or material is changed or altered so that it exceeds the lead content limits.

Okay, so what products or material are exempt? The rule is long, so I’m going to tackle this in parts.

TEXTILES

After reviewing the data submitted, the CPSC is exempting textiles from the lead content limits. The CPSC concludes that generally textile materials and products do not contain lead and have not undergone any processing or treatment that imparts lead resulting in a total lead content that exceeds the CPSIA total lead limits.

Natural Fibers

With respct to natural fibers, the CPSC finds that they are natural materials and do not contain lead, whether they are dyed or undyed.  Examples of plant based fibers, from the seed, stem, or leaves of plants, include, but are not limited to, cotton, kapok, flax, linen, jute, ramie, hemp, kenaf, bamboo, coir, and sisal. Animal fibers, or natural protein fibers, include but are not limited to silk, wool (sheep), and hair fibers from alpaca, llama, goat (mohair, cashmere), rabbit (angora), camel, horse, yak, vicuna, qiviut, and guanaco.

Manmade Fibers

Manmade fibers are also included. Manmade (or manufactured) fibers are created by technology and are classified as regenerated, inorganic, or synthetic. Regenerated fibers are made from natural materials that are reformed into usable fibers. These fibers include, but are not limited to, rayon, azlon, lyocell, acetate, triacetate, and rubber. Synthetic fibers are polymers created through a chemical process and include but are not limited to polyester, olefin, nylon, acrylic, modacrylic, aramid, and spandex. The CPSC concludes that these fibers also generally meet the lead limits.

Dyes and Pigments

Dyes and pigments used on textiles are also excluded, but pigments used on non textile applications are not because they may contain lead. So, the exemption extends to dyes and pigments but not to “after-treatment applications, including screen prints, transfers, decals, or other prints.”

5 Simple Steps for Summer Toy Safety

summer beach toysSchool is almost out and the lazy days of summer are here. Well, perhaps lazy isn’t accurate if you are a mom – summer can just mean listening to whines of “I’m so boooored” (drawn out as only a child can do) or schlepping from one activity to the next.

But summer should be about play. About discovering tadpoles turning into frogs in the local pond. About poking bugs, turning over rocks, or swinging from swings. Long afternoons perfecting a skateboard trick. Hosting outdoor tea parties for dolls. And, summer means bringing out the summer toys. Dump trucks, gardening spades, sand pails.

 

Outdoor play is great to keep kids healthy. But, before you turn the kids loose, review these easy steps to take to make summer play a littler safer from Malcolm Denniss, Technical Director for SGS Consumer Testing Services.
 
1)      Check the protective gear. My 6 year old can already do some wicked tricks on his skateboard, but he wears protective gear. Malcolm emphasizes that protective gear is most important for kids out on their bikes, skate boards and other riding toys. Of course, helmets must fit correctly. He reminds us to make sure that last year’s helmet still fits before using it. 

2)      Use the right protective gear. Malcolm urges parents to make sure that they use the right gear. Remember there are different types of helmet for different activities. 

3)      Teach kids to stay safe. Malcolm believes kids can always use a reminder to stay away from traffic areas such as roads parking lots and driveways. 

4)      Pool safety.  With summer comes pool fun. However, Malcolm advises that all pools should be properly protected with fences and self closing gates to ensure very young children cannot access the pool without adult supervision. 

5)      Check outdoor toys. Toys left outside weather. Before you let kids play with sand toys, dump trucks, gardening tools and other outdoor play items, just check them over carefully to make sure they haven’t deteriorated. A quick check can tell you whether a metal truck is rusty and has sharp edges. 

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.

CPSIA FAQ #2: Do I have to test products manufactured before February 10, 2009?

Updated January 15, 2009.  My husband actually read my blog, and said my answer below wasn’t that clear.  So I’ll try again.


Second in my so far pretty popular Consumer Product Safety Improvement Act (CPSIA) frequently asked questions is:


FAQ #2:  Do I have to test my existing inventory for lead?


So, as you probably know if you are even reading this post is that on February 10, 2009, the CPSIA establishes a lead content limit for children’s products of 600 parts per million (ppm).  For items manufactured after that date, and before August 14, 2009, the manufacturer of domestically produced products and the importer of foreign produced products must issue general conformity certificates (GCCs) certifying that the products meet that 600 ppm lead content.


Additionally, the CPSIA interprets the February 10, 2009 600 ppm lead content limit to apply to all children’s products, regardless of when they are manufactured.  In other words, the CPSIA is retroactive.  This is because the CPSIA defines those products that don’t meet the lead limit as being banned hazardous substances, and banned hazardous substances cannot be distributed in commerce.


But do you have to test products manufactured before 2/10/09? Not necessarily. The law itself doesn’t require you to test. You just can’t sell products that exceed the 600 ppm limit.  But the law doesn’t dictate what information you use to make that determination – you could use suppliers’ certifications.  You could use your knowledge about the manufacturing and components, provided it is informed.  And you can test.  According to CPSC spokesperson Julie Vallese in some raw interview footage, you just need to make an “informed decision” and have a “level of confidence.”


The no testing but can’t sell if limit exceeded may be a distinction without a difference.  You can’t legally sell children’s products that don’t meet the limit, and you may not have any idea without testing.  For most companies and businesses with inventory, they are going to have to do some form of testing, or get the information from the appropriate supplier.  You really don’t want to be arguing in court (such as a claim from a competitor for unfair competition) that you just looked at the products and made a decision.


Of course, if the product is a coated or painted product, it is subject to the lead in coatings rule and is subject to 3rd party accredited testing as of 12/22/08.


The CPSIA: Good in Theory, Hurting Small, Favorite Green Businesses in Practice

On August 14, 2008, President Bush signed into law the Consumer Product Safety Improvement Act (CPSIA).  It was drafted as a toy safety law in response, at least in part, to the numerous recalls in 2007 for lead in children’s toys and jewelry.  It was also drafted in response to the tragic death of a 4 year old after ingesting a charm that was almost pure lead.

It was designed to be a toy safety law, but its reach is much, much broader.  And, like all broadly written, reactionary laws, it has very significant, it appears largely unforeseen consequences.  Like perhaps putting out of business thousands of small manufacturers of children’s products, including some of my favorites – the small manufacturers of reusable cloth diapers, natural wood toys, handcrafted costumes, and innovative children’s products.

How can a law that was designed to protect us against the hazards of lead and phthalates result in closing the doors of the very companies that sell the alternative products I love?  

Well, let’s talk a little bit about the law.  Now, the CPSIA has several different provisions.  I’d like to focus on one.  The law creates a new standard for lead in children’s products.  In theory, a standard for lead in children’s products is great.  Everything I could ever want, especially since I routinely find lead in children’s products.  

The problem is in the implementation and testing to demonstrate compliance with that standard.  There are two groups of produts to which this standard applies:  the inventory in existence as of the date the standard becomes effective, and those products manufactured after the date the standard becomes effective.  The 600 parts per million (ppm) standard for children’s products becomes effective on February 10, 2009.  (Just a note – there is a separate standard for lead in paints and coatings.) 

First, let’s talk about what products are covered.  The standard applies to children’s products.  Children’s products are defined to be any product intended to use or marketed to children under the age of 12.  Clothing.  Toys.  Dress up costumes.  Sleeping bags.  Tableware.  Virtually any product that you can think of under the CPSC’s jurisdiction that is intended for use by children under the age of 12. 

Existing Inventory 

Existing inventory are those products already manufactured as of February 10, 2009.  The products on store shelves, on trucks and in boats, and sitting in warehouses.  According to an opinion issued by Cheryl Falvey, the Consumer Product Safety Commission’s (CPSC) general counsel, as of February 10, 2009, all children’s products that do not achieve the 600 ppm standard are considered banned hazardous substances and cannot be sold or distributed in commerce.  She states “[i]f children’s products with more than 600 ppm of lead are to be treated as banned hazardous substances, then the ban is applicable to that at the effective date of that treatment regardless of the date of manufacture of the product.”  Her conclusion?  “Products with more than 600 ppm of lead must come off the shelves no later than Febarury 10, 2009, 180 days after enactment.” 

So, this means all existing inventory as of that date must meet the standard or must be destroyed.  There is a sense of unfairness, since the law is retroactive.  You have to realize that the Spring lines have already been manufactured and shipped.  Many were manufactured and shipped before the law was even signed.  To be honest, I’m wondering if the retailers will seek a bailout.  Do you remember that after chlorinated Tris was banned, President Reagan signed legislation allowing companies to seek federal reimbursement of more than $50 milion in losses? 

Determining compliance for existing inventory is hard.  How do you demonstrate compliance for those products in inventory on February 10, 2009.  Just simply testing all of the products in inventory is expensive, and duplicative, if 10 retailers test the same product.  Third party certification is not required for this inventory, but a person or company will need to know if the products comply with the law.  The sellers at Etsy are up in arms.  So are the sellers on eBay.  There’s a blog out there focused on the CPSIA calling February 10, 2009 National Bankruptcy Day.  The Fashion-Incubator’s forum on the CPSIA has been opened to non-members. 

Part of the problem is that there is a lot of misinformation floating around about the CPSIA.  And one of the pieces of misinformation is that all inventory will have to be tested by an accredited third party at an enormous cost.  And yes, third party testing is extremely costly.  It would be prohibitive for most to complete 3rd party testing for existing inventory.  But it is not accurate to say that 3rd party testing is required for existing inventory – it is not required.  One option is to use an XRF analyzer as part of a reasonable testing program for existing inventory and to issue general conformity statements (for manufacturers).  The CPSC specifically stated this is an option in the FAQ’s for the CPSIA.  (Shameless plug – I can use my Niton XRF Analyzer to test existing inventory for lead.) 

But determining whether inventory meets the lead standard is extremely burdensome and very difficult for retailers, distributors and manufacturers.  Without testing, you really cannot know if a particular product meets the standard.  Plus, this doesn’t even address the financial implications related to loans on inventory – inventory which may not be worth anything. 

New Products 

The second part of the requirement is that all products must be tested by an accredited third party.  This provision applies differently because the CPSIA states that the testing requirement “shall apply to any children’s product manufactured more than 90 days” after the CPSC publishes a notice of the requirements for accreditation for 3rd party testing.  That requirement will apply 90 days after the CPSC publishes its notice – which the law requires that it do for the August 2009 lower standard of 300 ppm lead for children’s products no later than May 16, 2009. 

Until the notice is published, according to the CPSC’s Frequently Asked Questions, children’s products manufactured after 2/10/09, will need a general conformity certification based on a test of the product or a reasonable testing program for products.  (Shameless plug – which is good news for me since my Niton XRF Analyzer can be used to satisfy that requirement according to the CPSC.  So, if you need assistance testing your inventory, I do offer consulting & testing services.) 

But once that 3rd party testing is required, manufacturers, even small manufacturers, are going to have a very hard time.  That testing is expensive.  And how the testing must be performed makes it extremely expensive.  For a very clear explanation of what needs to be testing, what SKUs have to do with it, and unit v. batch testing, read Greco Woodcrafting’s Weblog entitled National Bankruptcy Day

But think about it – does it make sense for an organic cotton t-shirt maker without any decals or logos that might have lead test for lead?  Or a manufacturer of woods toy finished with beeswax test for lead? 

Selecta Spielzeug has already announced it is pulling out of the US market and will cease distributing as of December 31, 2008.  Its decision is based on cost – it cannot afford the new testing requirements for its beautiful wood toys finished with beeswax.  Z Recommends has the details on Selecta’s decision.  Plus, Z Recommends points out those Selecta products previously positively reviewed. 

HABA will not sell its jewelry in the US any longer.  

But I’m more concerned about the small manufacturers profiled at the Handmade Toy Alliance.  Like Fuzbaby, who will not be able to afford testing its resuable cloth diapers.  Or the absolutely adorable Kallisto Organic Bears from Challenge & Fun.  And lots of others too. 

I’ll be posting over at Healthy Child Healthy World on the phthalate portion of the CPSIA next. 

If you are inclined to be an activist, and I think we all need to be to protect the small manufacturers, including work at home moms, write to your legislators to address these implementation problems with the CPSIA.  Handmade Toy Alliance has tips for taking action.  Or submit letters using this link

Here’s the thing – no sane person wants unsafe children’s products.  But tell your legislators that products made from materials unlikely to contain lead should be exempt, such as unadorned textiles and beeswax finished wood.  If you need some pointers and some talking points, Nature’s Child has a great outline.

Animalz Toys – Organic Maple – at Target

Well, I just got back from shopping at Target and was surprised to find Animalz in the Toy section.  Animalz are natural wooden anmals made from organic maple at a pretty good price point.  I picked up the horse for my nephew for $5.99.  Target had toys from the Safari line and the Farm line.  Target also had a 3 piece play set of Artic animals.  I was pretty excited to find such a great product at a large retailer like Target.  I was excited when my Target started carrying Seventh Generation and Mrs. Meyer's cleaning products.  But this makes me very happy.