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Product Safety Group Seeks Input On Lead Limits

Issue: 2008sep


The Consumer Product Safety Commission (CPSC) invites comments on several portions of the new Consumer Product Safety Improvement Act (CPSIA) which relate to children’s products containing lead. This is your opportunity to voice your concerns about certain aspects of this new law that went into effect in August 2008. Under the terms of this law, a children’s product is defined as being appropriate for a person under the age of 12.

The Commission staff is interested in comments and information regarding:
• The identification of any component part of any children’s product that currently contains lead in any concentration
• Whether any children’s product currently on the market contains lead-containing component parts that are inaccessible, and the reasons why such component parts are considered inaccessible (keeping in mind that the CPSIA excludes paint, coatings or electroplating as barriers with respect to accessibility by children)
• Whether test methods or processes exist that are used or may be used to assess the accessibility by children of component parts of products.

Additionally, the CPSC staff in interested in comments and information pertaining specifically to certain electronic devices:
• The identification of children’s electronic devices for which lead is currently used in any concentration in any part or component of the product.
• Whether it is technologically feasible to achieve in all parts of children’s electronic devices the 600 ppm lead limit; the 300 ppm limit; the 100 ppm limit
• Whether any children’s electronic product currently on the market contains lead-containing component parts that are inaccessible, and the reasons why such component parts are considered inaccessible
• Current compliance with or possibility of compliance with regulations, such as the European Union directive on the restriction of use of hazardous substances or other standards.

Please submit all comments and information to Anne Lardner, AnneL@ppai.org or 972-258-3041 no later than October 12, 2008. Staff will compile all comments and information and forward it to the Office of the Secretary for the CPSC.

To access the CPSIA law in its entirety, click here. To view a recent webinar produced by PPAI on this subject, click here.


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