Math-U-See Blog

Update:

The CPSC has clarified much of the ambiguity in the CPSIA, you can read the full statement here.

Manufacturers, importers, distributors, and retailers should also be aware that CPSC will:

• Not impose penalties against anyone for making, importing, distributing, or selling
  • a children’s product to the extent that it is made of certain natural materials (pdf), such as wood, cotton, wool, or certain metals and alloys which the Commission has recognized rarely, if ever, contain lead;
  • an ordinary children’s book printed after 1985; or
  • dyed or undyed textiles (not including leather, vinyl or PVC) and non-metallic thread and trim used in children’s apparel and other fabric products, such as baby blankets.

    (The Commission generally will not prosecute someone for making, selling or distributing items in these categories even if it turns out that such an item actually contains more than 600 ppm lead.)

  Sellers will not be immune from prosecution if CPSC’s Office of Compliance finds that someone had actual knowledge that one of these children’s products contained more than 600 ppm lead or continued to make, import, distribute or sell such a product after being put on notice. Agency staff will seek recalls of violative children’s products or other corrective actions, where appropriate.

• Issue an interim final rule (pdf) effective February 10, 2009, which establishes alternative lead limits for certain electronic devices, in order to prevent unnecessary removal of certain children’s products from store shelves.
• Accept a manufacturer’s determination that a lead-containing part on their product is inaccessible to a child and not subject to the new lead limits, if it is consistent with the Commission’s proposed guidance or is based on a reasonable reading of the inaccessibility requirement. Paint and other coatings or electroplating are not considered barriers that make a component inaccessible.

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Many of you have contacted us asking if we were aware of the new Consumer Product Safety Improvement Act (CPSIA) going into effect on Feb 10th and asking if we would be in compliance by then.

I just wanted to take a minute and thank you all for your concern and information you have provided. We are aware of the new regulations and have been working to make sure that Math-U-See continues to comply with any and all safety regulations.

Here is a brief rundown on our products and where they are manufactured.

• Books - Printed locally in PA
• DVDs - Replicated in FL
• Blocks - Manufactured locally in PA
• CDs - Duplicated locally in PA
• Shipping Material - Manufactured locally in PA

Whenever possible we use local resources and businesses to supply our needs. I was just on the phone with our block manufacturer and he informed me that he hasn’t been able to purchase plastic with lead in it since the 1970’s.

In summary our products are already safe, and all we will have to do by Feb 10th is pay for testing (can be expensive) so we can receive a certificate saying that yes, our products are safe. Unfortunately many home based businesses will not be able to afford testing. Hopefully the regulations can be modified so that children are protected from lead exposure while ensuring that small businesses can continue to do business.

Helpful Links:

• CPSC - Clarification letter on selling used product
• CPSC - FAQ page
• LA Times - article on the need to rethink the testing regulations
• Handmade Toy Alliance download it could happen to you
• Rocks in My Dryer - The Scoop on the CPSIA
• Book Publishing and Lead Information
• Change.org - Save Small Businesses
• American Library Association - Impact of CPSIA on libraries
• iPetition - CPSIA impacts on Children’s clothing
• Fashion-Incubator - CPSIA Please Take the Economic Impact Survey

If you have any other helpful links please post them in the comments.