Lead, Phthalates, and Inaccessible Parts

Knowing what needs to be tested and more importantly what doesn't, is a common theme we see with inexperienced manufactures, importers and retailers. 

Did you know that parts that are not easy accessible through normal use, do not need to be tested for Lead or Phthalates? 

According to the CPSC, ''lead and phthalate limits shall not apply to any component part of a children’s product that is not accessible to a child through normal and reasonably foreseeable use and abuse."

One of the most common places where testing costs can be reduced is by understanding the differences between these accessible parts and inaccessible parts.

So how do we determine if a part is inaccessible? According to the CPSC a component part is not accessible if it is:

• Not physically exposed by reason of a sealed covering or casing 
• Does not become physically exposed through reasonably foreseeable use
• Abuse of the product including swallowing, mouthing, breaking, or other children’s activities, and the aging of the product, does not case the part to become accessible 
• Parts do not become explodes after the CPSIA Physical/Mechanical test.

Please note that paint, coatings, fabric, or electroplating may not be considered to be a barrier that would render a part to be inaccessible.

We often see a business submit a product or a component to a laboratory for testing without stating certain areas of inaccessibility. The lab will then either A) assume the parts are accessible or B) flat out charge the extra testing cost if the business did not ask for the exemption. 

In short, take the time to determine parts that are inaccessible in your product and more importantly make sure to review with the lab any reasons why inaccessible parts were wrongfully tested.

As always,  please feel free to send your comments/questions to QualityAssurance@cptsol.com

CPTS