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Focus On Balloons. Presented by: Haley Sprague and Jennifer Buoniconti, UL Mark Jenkins, Pioneer Balloon.
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Focus On Balloons Presented by: Haley Sprague and Jennifer Buoniconti, UL Mark Jenkins, Pioneer Balloon
This information is being furnished by PPAI for educational and informational purposes only. The Association makes no warranties or representations about specific dates, coverage or application. Consult with appropriate legal counsel about the specific application of the law to your business and products.
Mechanical Hazards Toy Safety and Labeling Flammability Chemical Requirements General Labeling Packaging Balloon Requirements
Sharp Edges / Points It is not likely to detect sharp edges or points on a balloon, but other components sold with the balloon may present a hazard Small Parts Balloons are exempt from 16 CFR 1501 Any components sold with the balloons must comply Bite Test (Mouth Actuated Toys) Mouth intended toys are tested at 100 pounds evenly applied for 5 seconds and maintained for an additional 10 seconds Mechanical Hazards
Use and Abuse Testing Simulate the exposure of a toy to mechanical damage through dropping and other actions likely to performed by a child during reasonable foreseeable use and abuse. After testing the toy is examined for mechanical hazards Toy Safety – ASTM F963-11
Material Quality Toys may be made from new or reprocessed materials and must be visibly clean and free from infestation. Safety Labeling Packages containing latex balloons and toys or games containing latex balloons shall comply with the labeling requirements of 16 CFR 1500.19 Toy Safety – ASTM F963-11
Product is considered a flammable solid if ignites and burns along its major axis with a self-sustaining flame at a rate greater than 0.1 inch per second. Flammability
CPSIA Ban on Lead-Containing Paint • 16 CFR 1303 in effect since 1978 at 600 ppm • As of August 14, 2009, 90 ppm limit • Compliance is required • GCC/CPC is required • Can test at ink stage, must have “traceability” • Third party testing is required • Composite Testing is allowed • Wet paint can be tested • HD XRF test method allowed
CPSIA Lead in Accessible Substrates • A substrate is the material of which something is made, and to which surface coating (i.e.. paint) may be applied • As of August 14, 2011, 100 ppm limit • Compliance is required • GCC/CPC is required • Component testing is allowed, must have “traceability” • Third party testing is required • Composite Testing of ‘like materials’ is allowed • XRF test method allowed
Material Testing Exemptions – Total Lead • Pure Wood (not plywood or other composites) • Paper • CMYK printing inks • Certain precious and semi-precious gemstones • Pearls • Stainless steel • Precious metals • Natural fibers (dyed or undyed) including, but not limited to: cotton, kapok, flax, linen, jute, ramie, hemp, kenaf, bamboo, coir, sisal, silk, wool (sheep), alpaca, llama, goat (mohair, cashmere), rabbit (angora), camel, horse, yak, vicuna, qiviut, guanaco • Manufactured fibers (dyed or undyed) including, but not limited to: rayon, azlon, lyocell, acetate, triacetate, rubber, polyester, olefin, nylon, acrylic, modacrylic, aramid, and spandex
Soluble Migrated Elements – ASTM F983-11 In surface coatings on toys, the following limits apply: - Soluble Antimony: 60 ppm - Soluble Arsenic: 25 ppm - Soluble Barium: 1000 ppm - Soluble Cadmium: 75 ppm - Soluble Chromium: 60 ppm - Soluble Lead: 90 ppm - Soluble Mercury: 60 ppm - Soluble Selenium: 500 ppm Note: If less than 10 mg of surface coating is present on the toy, the surface coating is exempt from Soluble testing.
Soluble Migrated Elements – ASTM F963 In substrates of toys, the following limits apply: - Soluble Antimony: 60 ppm - Soluble Arsenic: 25 ppm - Soluble Barium: 1000 ppm - Soluble Cadmium: 75 ppm - Soluble Chromium: 60 ppm - Soluble Lead: 90 ppm - Soluble Mercury: 60 ppm - Soluble Selenium: 500 ppm
CPSIA Prohibition on Sale of Certain Products Containing Specified Phthalates • Applies only to Children’s Toys and Child Care Products • For all such products, DEHP, DBP, BBP – limit of 0.1% • For all such products or any part of the product that can be placed in a child’s mouth: DINP, DIDP, DnOP – limit of 0.1% (interim prohibition) • Applies to accessible materials only (before and after use and abuse testing)
CPSC Phthalate Guidance Phthalates may be found in following materials: • Soft or flexible plastics, except polyolefins • Soft or flexible rubber, except silicone rubber and natural latex • Foam rubber or foam plastic such as PU foam • Surface coatings, non-slip coatings, finishes, decals, printed designs • Elastic materials on apparel, such as sleepwear • Adhesives and sealants Phthalates would not likely be found in the following materials: • Unfinished metal • Natural wood, except coatings and adhesives added to wood • Textiles, except printed decorations, waterproof coatings, elastic • Mineral products such as sand, glass, crystal
Illinois Lead Poisoning Prevention Act: Warning Statement Requirement • A warning statement is required for the toys containing paint with a specified Lead content in their surface coatings • If > 40 ppm but < 90 ppm of Lead is present, a warning statement is required “WARNING: CONTAINS LEAD. MAY BE HARMFUL IF EATEN OR CHEWED. COMPLIES WITH FEDERAL STANDARDS.”
CPSIA Tracking Label • Permanent, distinguishing marks on product (to the extent practicable) and packaging manufactured as of Aug. 14, 2009 • Required for all children’s products, both imported and domestically manufactured • Basic information required: • Manufacturer or private labeler name • Location of production • Date of production • Other tracking information (batch, run number, sources)
Tracking Labels • The CPSC has not issued firm direction on: • What is meant by “to the Extent Practicable” • The size and location of the label • The Federal Care Labeling rules can be a guide on what is practicable labeling • When evaluating your labeling, the CPSC will consider the reasonableness of your marking/labeling decision and consider the practices of your peers. • Therefore, markings on hangtags or adhesive labels do not meet the “permanent” requirements.
PPAI Tracking Label System • PPAI has developed an electronic system for maintaining the tracking label information with a URL code on the product and packaging itself. • Additional details on this system are available through PPAI.
Country of Origin Marking 19 CFR 134.11 Every article imported into the US must be marked with country of origin Producer Markings ASTM F963 Principal component of the toy or the packaging must be marked with the name and address of the producer or distributor. General Labeling
NERC Toxins in Packaging • Developed in 1989 to reduce the amount of four heavy metals in packaging components distributed in the United States • Has been adopted by nineteen states • The sum of the concentrated levels of incidentally added Lead, Mercury, Cadmium and Hexavalent Chromium present in any packaging component cannot exceed 100 ppm
Plastic Bag Suffocation Warning • Labeling and warning requirements for certain plastic bags California, Massachusetts, New York, Rhode Island and Virginia "WARNING: To avoid danger of suffocation, keep this plastic bag away from babies and children. Do not use this bag in cribs, beds, carriages or play pens. This bag is not a toy."
Product Safety Resources • PPAI: www.ppai.org • Product Safety powered by PPAI: http://www.ppai.org/inside-ppai/product-safety/ • Consumer Product Safety Commission: www.cpsc.gov, www.recalls.gov, www.cpsc.gov/PromotionalProducts/ • UL: www.ul.com or Haley.Sprague@ul.com • Questions? AnneL@ppai.org
Thank you! Questions?