Does anti-lead mean anti-toy?
What ever happened to that lead-in-toys law? My woodworking club wants to start making toys for Christmas charities soon, but we're worried we'll run afoul of the law.
—Robert Shultz, South Point, Ohio
Recent updates to the Consumer Product Safety Improvement Act (CPSIA) could affect your plans, Robert. A quick refresher: In 2007, several toy companies' imported products were found to contain illegal amounts of lead. In response, Congress enacted the CPSIA, which requires manufacturers to provide documentation from third-party labs certifying that their childrens' products meet minimal lead and phthalate (plastic softeners) limits.
Following outcries concerning the high cost of testing, the Consumer Products Safety Commission (CPSC), charged with CPSIA enforcement, twice pushed back the compliance deadline in order to interpret the broadly-worded law to February 10, 2011. Unfortunately for woodworkers, finishes were not covered by this deadline extension. So, adding a finish to your project invokes the third-party testing requirement today.
However, the CPSC has adopted an interim policy of "component testing," meaning if woodworkers can provide documentation from all of their suppliers that hardware, glue, finish, etc. have been tested and certified by third-party labs to meet the lead requirements, then the complete product is in compliance. This has the potential to shift the burden of expensive third-party testing from the woodworker to the component manufacturers. Contact the manufacturers to see if they have such documentation.
The fact that your club is creating the items for charity, rather than for sale, doesn't let you off the hook. According to Patty Davis, CPSC spokesperson, "Regardless of whether you're selling it or giving it away, if it's for a child, it needs to be in compliance with the law."