My Michelle Clothing Recalled For CPSIA Lead Content Violation

The Consumer Product Safety Commission (CPSC) announced yesterday a voluntary recall of certain girl’s clothing for violation of the Consumer Product Safety Improvement Act’s (CPSIA) lead content standard. The clothing items were distributed under the name My Michelle and sold at Dillard’s, Burlington Coat Factory, Kohl’s and others. The decorative trim and attached necklaces on the clothing items have lead present above the current 300 parts per million (ppm) limit under the CPSIA.

This recall is interesting because it deals with the decorative trim items attached to clothing. Now, if you aren’t familiar with the CPSIA, let me briefly explain that the CPSIA established a lead content limit for children’s products or any part of any children’s product. The current limit is 300 ppm, and that limit is to drop to 100 ppm in August of this year unless the CPSC finds it technologically infeasible (or there is some legislative fix). Children’s products include clothing, so all parts of children’s clothing must meet the 300 ppm lead content limit.

For most fabrics, this is easy. The CPSC has deemed most textiles (undyed and dyed) to be compliant with the forthcoming 100 ppm lead content limit. So, a lot of children’s clothing manufacturers have basically starting ignoring the CPSIA since most fabrics and thread don’t need to undergo any testing to meet the lead content standard (although this ignores the other requirements, including permanent tracking labels and general textile flammability). But add bling to clothing, and you’ve got a problem. And manufacturers and importers should not forget that.

Why is this? Because a lot of bling can’t pass the lead content limits. Most true crystals – meaning glass with lead added such as the Swarovski crystals – just can’t pass. Most Swarovski crystals test at around 240,000 ppm lead. There may be no reasonable expectation of an exposure to the lead in a crystal matrix, but the CPSIA isn’t based upon exposure. No. It is based upon a limit of total lead content. So those crystals are out.

That is also true of a lot of the decorative glass beads. Those fabulous colors inside the bead often have lead in them. So they can’t be added to children’s clothing even though no risk of exposure exists.

I’ve seen a lot of children’s clothing in the marketplace recently decked out with all sorts of bling. The look of attached necklaces and other jewelry seems to be in for the tween crowd. But making sure that bling is compliant is important (even if you debate the merit of the requirement).

AIHA Responds to USA Today Article

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.

TheSmartMama Investigates – Found Cadmium Jewelry at Target

After the Associated Press released the results of its investigation evaluating toxic cadmium in children’s jewelry on Sunday as a substitute for lead, I posted that using cadmium in jewelry pre-dated the lead content limits of the Consumer Product Safety Improvement Act (CPSIA), but that I had seen an upswing in cadmium in jewelry and vinyl since the CPSIA. Cadmium in jewelry seems to have been more widely used since 2003, when cadmium prices dropped.  The thing about cadmium is that it is shiny, strong and malleable at low temperatures – lower temperatures than zinc, the usual substitute for lead in jewelry.

I also decided to use my Niton XRF analyzer to do some super sleuthing a la Nancy Drew.

target necklaceI purchased two necklaces from the girls’ section at Target on December 12, 2009. These necklaces are clearly intended for children – they are sold in the girl’s clothing department and the length is shorter than what would be common for an adult. So, I tested them. One tested fine, but the other tested high for cadmium. Using the Niton XRF analyzer, the heart shaped charm tested at 22,000 ppm cadmium and the star shaped charm tested at 64,000 ppm. Now, the “rhinestones” interfere a bit with the results, as does the shape of each charm, and since I didn’t want to damage the piece, I didn’t pry out the “rhinestones” or hammer the shape into something a bit easier to test. So, if Target was my client, then I would recommend wet testing to verify the results. But there is no doubt that both of these charms contain cadmium.

Charms are always problemmatic because kids have a tendency to stick them in their mouth. While these are intended for children old enough to know NOT to stick them in their mouths, I know that virtually every little girl I know mouths or sucks on their necklaces. Cadmium is a problem if swallowed, and can also result in low level exposures just from mouthing,

I know that since the Associated Press broke its story, the Consumer Product Safety Commission (CPSC) has reacted quickly to address the issues. CPSC Chairwoman Inez Tenenbaum has made remarks at an international toy fair in Hong Kong urging manufacturers not to substitute cadmium in place of lead.

I had a great conversation with Scott Wolfson, CPSC spokesperson. It was actually a pleasure to speak with him, and his comments emphasized the dramatic change at the CPSC under President Obama. He stated that the CPSC is aiming for true clarity in the Asian marketplace, which seems very consistent with Tenenbaum’s comments in Asia following the cadmium. Wolfson however did state that parents may want to steer clear of lower cost jewelry if they are concerned about exposure.

Cadmium in children’s jewelry isn’t regulated under the CPSIA. There is a standard for soluble cadmium in paints and coatings used on children’s toys, but this standard isn’t applicable to metal worked into children’s jewelry. However, the CPSC can address the issue under the Federal Hazardous Substances Act (FHSA). The CPSC can find the jewelry items to be “banned hazardous substances” under the FHSA if it finds that the items contain quantities of cadmium sufficient to cause substantial illness as a result of reasonably foreseeable handling or use, including reasonably foreseeable ingestion by children.

And this seems like good advice in light of  comments from jewelry industry representatives like He Huihua, manager of the Suiyuan Jewelry Shop in Yiwu. As reported by the Associated Press, he stated, “We just make what our clients order. If they pay more, we use the better raw material, and vice-versa. From a few cents to a few dollars, we can make the same style of jewelry product with a different raw material.” In response to a question regarding the health risks associated with cadmium, he answered “I can’t be overly concerned about that.” The AP reports “interviews with more than a dozen manufacturers and sellers in Yiwu confirm that cadmium is a common ingredient in the earrings, bracelts, charms and other baubles being churned out by local factories.”

When it comes to jewelry, zinc alloys cost more than cadmium, so with everybody wanting lower prices, substituting cadmium seems to make financial sense. Unfortunately.

Understanding the CPSC’s new CPSIA Interim Enforcement Policy – Step 2: Does it have a coating?

Okay, so yesterday I posted about the Consumer Product Safety Commission’s (CPSC) new Interim Enforcement Policy regarding lead paint and lead content limits under the Consumer Product Safety Improvement Act (CPSIA). The threshold question discussed was the determination of whether the product at issue is a children’s product.

If it is a children’s product, then I think the second question is whether the product at issue has any paint or surface coatings. Why does this matter? Because there are different limits for lead in paints and coatings than the general lead content limit applicable to children’s products.

The term “paints and other similar surface coating materials” are defined to mean a fluid, semi-fluid, or other material, with or without a suspension of finely divided coloring matter, which changes to a solid film when a thin layer is applied to a metal, wood, stone, paper, leather, cloth, plastic, or otehr surface. (16 CFR 1303.2(b)(1).) The term excludes printing inks or those materials which actually become a part of the substrate, such as the pigment in a plastic article, or those materials which are actually bonded to the substrate, such as by electroplating or ceramic glazing.

So, once you have determined that the product is a children’s product, then you must determine whether the children’s product has any paints or coatings on any of its parts. If the answer is yes, then for those painted or coated parts, the product must comply with the lead limits for paints and coatings. For those products manufactured before 8/14/09, the lead limit in the paint or coating is 600 ppm. For those products manufactured after 8/14/09, the lead limit in the paint or coating is 90 ppm.

If the product does not meet those standards, it is unlawful to sell, offer for sale, manufacture for sale, distribute in commerce or import the product into the United States. Produdcts that do not comply are banned under the Federal Hazardous Substances Act.

While the requirement for CPSC accredited third party testing for the general lead content has been stayed until 2011, the requirement that CPSC accredited testing for lead in paints and coatings was not stayed. All children’s products with paints and coatings manufactured after 12/22/08 must have CPSC accredited third party laboratory testing to demonstrate compliance with the lead limits for those parts with paints or coatings. So, that means for products manufactured after 12/22/08 must have accredited certification that they meet the 600 ppm limit, and products manufactured after 8/14/09 must have accredited certification that they meet the 90 ppm limit.

The test method to be used is set forth on the CPSC’s website. Note that the CPSC may use XRF testing to screen painted products, but the testing to be done for certification for painted products that required accredited third party testing is a digestive method. To find an accredited laboraty, use the CPSC’s website and use the “narrow the laboratory list” function to identify laboratories accredited for lead in paints and coatings.

Okay, so do you have to test the final product? Well, the CPSIA intends that certification be based upon testing of the final product. So, paint samples have to be scraped off the final product. However, the CPSC has recognized that this may be difficult – particularly for parts that are small. It may mean numerous samples must be destroyed to collect enough of the same paint to test (note that you CANNOT composite (or aggregate) different types of paint for testing). So, the CPSC has staetd that it will allow certification of a children’s product as being in compliance with teh 90 ppm lead paint limit if, for each paint used on the product, the manufacturer or importer has a test report based upon the final product or based upon the paints used on each part. Also, you need to be able to trace each batch of paint used on the product to the paint manufacturer. You have to be able to link up your certification with the paints used.

Note that the lead limits in paints and coatings is not limited to children’s products.

CPSC Extends CPSIA Lead Content Testing and Certification for another year!

XRF analyzer on toys

XRF analyzer on toys

I haven’t had time to digest this yet but I had to post that the Consumer Product Safety Commission (CPSC) has voted to extend the lead content testing and certification stay for an additional year, or until 2/10/11.  This should provide welcome relief to many, many manufacturers. This means while children’s products must meet the current standard of 300 ppm total lead content limit, manufacturers and importers will not have to begin 3rd party testing as of 2/10/10.

And, this means that XRF testing can continue to be use to verify compliance for many products. So, if you need testing, just let me know.

CPSC Extends CPSIA Stay for Lead, Phthalates and More; Lifts Stay for Other

Update 12/17/09 – Well, the Consumer Product Safety Commission (CPSC) posted the documents discussed in this blog post prematurely, apparently. As discussed by Rick Woldenberg much better than I could ever say, things have changed – and the policy released and discussed below is no longer available on the CPSC’s website. Apparently, the document did not reflect what the CPSC had agreed to do.

Okay, if the CPSC can’t get it right, how exactly are manufacturers supposed to comply? In any event, I will provide an update when I can. I’m leaving the old post below . . . .

On December 15, 2009, the Consumer Product Safety Commission (CPSC) issued two different policies related to the Consumer Product Safety Improvement Act (CPSIA) which are a tad confusing but offer substantial relief to manufacturers and importers. If you are new to the CPSIA, then you may want to persue some of my earlier posts.

The first involves the CPSC’s decision to revise the stay of enforcement of certain testing and certification requirements. Remember, on February 9, 2009, the CPSC announced a stay of certain testing and certification requirements under the CPSIA until February 10, 2010. Under the Consumer Product Safety Act, as amended by the CPSIA, a manufacturer of a product that is subject to a consumer product safety rule under the CPSA or similar rule enforced by the CPSC must issue a certificate of compliance. Basically, the manufacturer is required to certify that the product complies with all rules, etc. Some categories of products such as children’s products were required to have certificates based upon third party accredited testing. But, for a variety of reasons, the CPSC stayed the testing and certification requirement so while products still had to meet the requirements, the testing and certification part was stayed, except for lead in paints and coatings, lead in metal children’s jewelry, cribs, pacifiers and small parts. So, for example, while children’s toys (without paint) must meet the current limit of 300 parts per million (ppm) lead in any component, a manufacturer is currently not required to have accredited third party testing to establish compliance.

But, the end of the stay was fast approaching, and the CPSC is behind on promulgating requirements for some categories. For other categories, the CPSC has issued requirements. So, the Consumer Product Safety Act: Notice of Commission Action on the Stay of Enforcement and Testing and Certification Requirements lifts the stay for some categories and extends the stay for others.

So, for bicycle helmets, dive sticks and similar articles, rattles, and bunk beads, the stay will be lifted on February 10, 2010, and those products will be subject to the specified testing and certification requirements for those manufactured after February 10, 2010.

For bicycles, the stay is extended until August 10, 2010 because of insufficient laboratory capacity for third party testing.

For lead content in children’s products (other than lead in metal children’s jewelry and lead in paints and coatings used on children’s products), the CPSC has extended the stay until August 10, 2010. This is welcome relief for many manufacturers. The CPSC indicates that it is extending the stay to allow component testing and to complete a rule on what constitutes a children’s product under the CPSIA. So, this means that until August 10, 2010, in accordance with the procedures the CPSC has published, manufacturers and importers can continue to use XRF technology, for example, to determine compliance with the 300 ppm total lead content limit.

Most importantly, the CPSC is continuing the stay until further notice for phthalates. Remember, in sum, certain phthalates are limited to 1,000 ppm in children’s toys and in child care articles. The term child care article is defined as a product intended for children under the age of 3  year that facilitates sleeping or eating. This is welcome news as no laboratories are CPSIA third party accredited for phthalate testing.

The CPSC is continuing the stay of testing and certification also for the requirement that children’s toys meet the ASTM F963 standard. So, toys manufactured must still meet the standard, but a manufacturer does not have to certify using third party testing.

The CPSC also issued an Interim Enforcement Policy on Component Testing amd Certifications of Children’s Products and Other Consumer Products to the August 14, 2009 Lead Limits. The August 14, 2009 lead limits are the revised lead limits for lead in paint in coatings, which dropped from 600 ppm to 90 ppm, and the total lead content limit, which dropped from 600 ppm to 300 ppm. I’ll talk about it more later.

Good Guide Admits Used Wrong Test for Zhu Zhu; CPSC Finds No Violation

After I took a bunch of flack for raising concerns about Good Guide’s testing of a Zhu Zhu Pet and its applicability given that the applicable US standard is for soluble antimony, not total, I feel vindicated. Completely. Today, the Good Guide issued a press release admitting that it used the wrong test to compare its toy testing results to the US standard. If you didn’t read the first post, basically, Good Guide claimed that the wildly popular Mr. Squiggles was full of toxic antimony and violated US standards. But I cried foul, pointing out that the Good Guide was using XRF analysis, which only tests for total, and the applicable US standard for children’s toys is no more than 60 ppm soluble antimony in paints and coatings. So, the Good Guide’s claim that the Zhu Zhu Pet violated US standards based upon its XRF testing was patently false.

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.

Zhu zhu pets, antimony, the Good Guide and misleading the public

Mr. SquigglesI have to say I’m more than a little upset about the recent publicity the Good Guide has achieved with its press release claiming that one of this year’s hottest toys – Zhu Zhu pets – contain dangerous levels of antimony. I mean, I want to support an effort like The Good Guide – giving the public ratings on the overall “greenness” of consumer products. But not if the organization is going to falsely claim a hazard.

Here’s the basic story – The Good Guide claims that Zhu Zhu pets are hazardous because antimony was detected at 103 parts per millinon (ppm) in one of the hamster’s fur, and 90 ppm in a nose, and The Good Guide asserts that the current standard is 60 ppm.

But that is wrong. The current US standard is 60 ppm soluble antimony in paints and surface coatings used on children’s toys, not total antimony. And that is a big difference. BIG difference. Reviewing the Good Guide’s listing for the basis for its rating, it states that antimony was detected using XRF technology. This is confirmed by Good Guide’s description of the toy testing efforts, wherein it states that the toys were tested using XRF. Now, if you read this blog regularly, you’ll know a I have a Niton XRF analyzer. And here’s the thing. As much as I love my XRF analyzer, it just can’t tell you soluble. At all. It only tells you total – total lead, total antimony, total mercury, etc. So the Good Guide is comparing apples and oranges, and raising a big stink. And that is wrong.

If you want to know, here is a description of the relevant standard for toys. It is a standard for heavy metals applicable only to paints and surface coatings, and applicable ONLY to toys  manufactured after 2/10/09. The description is from the Consumer Product Safety Commission (CPSC):

The Standard Consumer Safety Specification for Toy Safety, ASTM F963-07 becomes a mandatory consumer product safety standard on February 10, 2009. This standard additionally places limits on the amount of lead (and other heavy metals, namely antimony, arsenic, barium, cadmium, chromium, mercury and selenium) based on the soluble portion of that material using a specified extraction methodology given in the standard. Toys manufactured after February 10, 2009, will have to meet these requirements.

In other words, the standard is based upon the soluble (also sometimes referred to as the leachable) portion, and only that. And, by the way, you can only determine the soluble portion using extraction methods. XRF just doesn’t qualify.

The Good Guide’s reference to an inapplicable standard is just wrong. You can’t say a company is violating a standard that doesn’t apply.

Plus, it does all of our efforts to reform chemical safety laws a great disservice. You can only cry wolf so many times before people stop believing you. You can’t cry “wolf” when the standard doesn’t apply. You just can’t get soluble results from any XRF analyzer. So shame on the Good Guide.

I call out greenwashing all the time. It goes both ways, you know?

Mama Got Her Gun on Fox & Friends

jennifertaggartfoxandfriendsI can’t believe I never blogged about this. Really can’t believe it. So, just a little bit late, I’m excited to announce that I appeared on Fox & Friends on July 18, 2009. I was supposed to talk about chemicals in common household products and simple steps to reduce exposure, but we got a little bit hung up on the Niton XRF analyzer and lead in toys and other consumer products.

So, here’s the clip of my little bit more than 3 minutes of fame.

Yep, mama got her gun on TV.

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.”