A few months back, there was a lot of discussion and speculation on the potential impact to woodturners, in particular toy makers, from the "Consumer Product Safety Improvement Act of 2008". Implementation of the act was pretty much put on hold last February, so the bureaucrats could figure out how this legislation would be administered. Well, the Act is scheduled to go into full-effect in about 90 days. And there is good news - the Government has finally come out with some pretty specific guidelines on how the new law will be interpreted. Here's the Government's "Statement of Policy" (pdf) - providing much needed clarification on administration of this new law.
There's a ton of more detailed information on the Act located here, but I think the bottom line for woodturning toy makers is that un-painted wood products, according to the Statement of Policy, are exempt from the third-party lead testing and marking requirements of the Act...as stated here:
"D. Must all children’s products be tested and certified for lead content?
Another common question is whether all children’s products need to be tested and certified for compliance with the new 300 ppm lead content limits. The law limits our ability to exempt products from the lead content limit. However, we have found that certain products, by their nature, will never exceed the lead content limit so those products do not need to be tested and do not need certifications to show that they comply with the law. These products include:
1. Precious gemstones: diamond, ruby, sapphire, emerald;
2. Semiprecious gemstones and other minerals, provided that the mineral or material
is not based on lead or lead compounds: e.g., aragonite, bayldonite, boleite,
cerussite, crocoite, galena, linarite, mimetite, phosgenite, vanadinite, and
wulfenite;
3. Natural or cultured pearls;
4. Wood (any paint on wood needs to be tested and certified);..."
And all this time I thought that "common sense" and "Government" were an oxymoron.
There's a ton of more detailed information on the Act located here, but I think the bottom line for woodturning toy makers is that un-painted wood products, according to the Statement of Policy, are exempt from the third-party lead testing and marking requirements of the Act...as stated here:
"D. Must all children’s products be tested and certified for lead content?
Another common question is whether all children’s products need to be tested and certified for compliance with the new 300 ppm lead content limits. The law limits our ability to exempt products from the lead content limit. However, we have found that certain products, by their nature, will never exceed the lead content limit so those products do not need to be tested and do not need certifications to show that they comply with the law. These products include:
1. Precious gemstones: diamond, ruby, sapphire, emerald;
2. Semiprecious gemstones and other minerals, provided that the mineral or material
is not based on lead or lead compounds: e.g., aragonite, bayldonite, boleite,
cerussite, crocoite, galena, linarite, mimetite, phosgenite, vanadinite, and
wulfenite;
3. Natural or cultured pearls;
4. Wood (any paint on wood needs to be tested and certified);..."
And all this time I thought that "common sense" and "Government" were an oxymoron.
