And today the Good Guide admitted that it used the wrong test to compare its results with the US standard. It stands by its results – and they are probably correct for what they are worth. The nose and fur of Mr. Squiggles may well have 93 and 106 ppm total antimony. But the Good Guide also admits that the US standard is for soluble antimony, and that it has no evidence whatsoever that Mr. Squiggles violates any US standard.

And then the Consumer Product Safety Commission (CPSC) confirmed that its review of the Zhu Zhu pet found no violation of the US standard for antimony.

Bottom line, it appears that Mr. Squiggles is in full compliance with existing US standards. Now, whether you are concerned about total antimony or not, that is a different question.

But, I’m still upset with the Good Guide and Dr. Dara O’Rourke. Both could have taken the time to have checked the relevant standards, assuming that this wasn’t a calculated effort to gain publicity by targeting the most popular holiday toy. Giving both the benefit of the doubt, I assume that they simply did not check the standard. Which is just amazing given the harm done by releasing these test results. Checking the relevant standard isn’t hard. In fact, it is right on the CPSC’s website for the Consumer Product Safety Improvement Act (CPSIA) in the frequently asked questions.

Moreover, the XRF technician should have advised them as well. I certainly advise my clients how XRF results can be used and the limitations, including explaining the difference between soluble and total results. I can’t imagine that the XRF technician did not know.

So that leads me to believe that this was a calculated stunt – and they got caught. Ultimately, I believe the fallout will be detrimental to all our efforts to reform chemical regulation policy in the US as consumer advocacy groups are branded “eco freaks” with alarmist claims of toxicity? So, Good Guide, was it worth it? If your publicity grabbing stunt means that the Million Baby Crawl is unsuccessful, are you pleased?

But I’m also a little annoyed with Zhu Zhu Pets. CEO of Cepia LLC (manufacturer of Zhu Zhu Pets, Russ Hornsby, derides XRF testing as unsound. That statement is also inaccurate. XRF analysis, as found by the CPSC, is accurate and sound if used properly – for example, it is perfectly acceptable for testing total lead in homogenous plastic as long as the equipment is properly calibrated against a known standard. It is also a very useful screening tool, and is widely used for that purpose, particularly by the CPSC and other regulatory agencies. But, I certainly agree with Cepia that it does NOT accurately measure for soluble concentrations and is not meant for that purpose.

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.

Are you worried about toxic chemicals in your home? 

Are you trying to make your home healthy? 

Are you looking to identify potential toxic chemicals in the home?

Do you have questions you want answered about your children’s exposures to toxic chemicals? 

Do you wonder whether your child’s toys are contaminated with lead, chromium or cadmium?

Do you want to know if you can do anything to reduce toxic chemicals in your home? Do you want to make a “green” non-toxic nursery or home?

Let me help! 

I’m available for home, telephone or shopping consultations.  I can help you create a nursery that is less toxic and more green.  Why should your mattress contain flame retardants, your crib offgas formaldehyde or the mattress cover contain phthalates?  I can help identify non-toxic alternatives. 

Worried about your household cleaners and what is in your shampoo and other beauty products?  I can also help you decipher labels and go shopping to replace products. 

I can also show you how to make green cleaners or personal care products at home, or just help you figure out what is good about what you have.  Let me come to your house and we will make green cleaners together, or diaper cream, or even a personalized perfume free of phthalates!  I bring the materials to you!

Test for lead in toys!  I can test your child’s toys and other household goods for lead, cadmium, chromium and several other elements, including bromine as an indicator of flame retardants.  I use a portable Niton XRF analyzer (an xray fluorescence analyzer).  We can check the toy box!  To read more about how the toy testing works, please read here.  This service is also great for day cares and schools.  Plus, I can test toys by mail – it is a small charge.  Just contact me to discuss.

Home consultations in the Los Angeles area are $200 for 2 and 1/2 hours. 

Another option – put a group together – we can do a healthy home workshop or toy test party!  Here are some group options:

• Ladies Green Night Out!  We can make our own perfume using organic essential oils.  You can have your own personalized scent, free of phthalates and synthetic ingredients.
• Eco-mamas.  Wondering how to make your own diaper cream and diaper wipes – grab some other moms and I’ll show you how. 
• Green your clean.  Want to green your cleaning – grab some like-minded folk and we will do that.  We can put together a variety of different cleaners and talk about the hazards associated with conventional cleaners. 
• Toxic toy box.  Wondering whether your toy box is toxic?  I can test toys too using an XRF analyzer.  It will test for lead, cadmium, chromium, mercury, bromine as a measure of flame retardants, chlorine as an indicator of PVC plastic and possibly phthalates, etc.

Some comments from happy clients:

On a Healthy Home Workshop:

I just wanted to give a shout out to Jennifer at TheSmartMama. She did an at home workshop for me and 8 friends last week and it was so informative. She had great handouts and answered all our questions.  She even checked out the ingredients in some of my stuff and used her lead reader to check my kids’ lunchboxes. If you know exactly what kind of questions you have and what you want to know more about- she will design a whole workshop around it. We did a basic overview because we were all pretty clueless. Anyway, I wanted to let everyone know what a great resource she is.

Los Angeles mom, Whitney.

On a Healthy Home Workshop:

Whoa. I just hosted a workshop in my home tonight with Jennifer
Taggart www.thesmartmama.com about toxins in the home-cleaners,
drinking cups, shampoos etc.

I have read so many new books on going green and toxic stuff in your
makeup and cleaning supplies that its overwhelming. I’m tired of the
fear mongering and just want someone with a good brain and a science
background to save me the full time job of deciphering all those
contradictory studies out there and weeding through all the web stuff
you read on these topics.

Jennifer not only knows what’s green but what’s safe…As green gurus
go, she’s really moderate and educated and as skeptical as I am about
what she reads.

I learned a ton from her workshop. She even tested some of my dishes
and toys for lead on the spot. I recommend her heartily.

I can’t wait until her book comes out. She does in-home consults for
a fee. What we did was get a bunch of friends together to split the
cost and gave her a list of concerns to speak to. It was fabulous and
a great bargain because we could share the cost. If anyone wants to
have her speak, let me know because I want to hear her again.

Los Angeles mom and business owner, Kayla.

On a Healthy Home Workshop:

I attended this workshop and walked away feeling soooo lucky that Jennifer is available and shares her intensive knowledge with us.  I don’t know if all of us on PH realize what a tremendous resource Jennifer is to us and believe me, I don’t think that, after the cost of printing booklets for us (which really could be sold as books in and of themselves) and giving so much of her time that she really made a penny.  She just knows and cares so much about us and our children!

Today Emily at Eden’s Closet hosted a free toy (and makeup) testing by “TheSmartMama” aka Jennifer Taggart. It was excellent. Jennifer (an environmental engineer) spent a lot of time testing a number of my son’s toys (she discovered one had way over the acceptable limit in ARSENIC!). Very knowledgeable — and comes to your home! A big thank you to Emily and Jennifer…

Los Angeles mom, Myra.

On a Healthy Home Consult:

I had Jennifer (the smart mama) come to my house last week to test my
children’s toys for lead, phthalates, and other toxic chemicals. She
tested my daughter’s bed as well, and we talked about easy ways to
further make my home ‘green’.

She is friendly and easy-going, and it was a joy to work with her.

I was so pleased, I just had to tell everyone.

Los Angeles mom, Caroline.

On a Healthy Home Consult:

I just had a consult with Jennifer Taggart, The Smart Mama, and I am so surprised that the drawer liners for my daughter’s dresser had an abundance of lead in them . . . and so many other things I would have never expected!!  I just moved into an older home that had been renovated so I wanted her to test many areas of the house.  What an incredibly valuable service she provides!! I wish I had done it sooner, as awareness is half the battle.  I cannot recommend her enough!!  Thanks again to peachhead for helping me to lear about so many things through so many wonderful people!!

Los Angeles mom Jennifer.