# CPSC Testing - What's Your Take?



## AtkinsonConsult (May 2, 2011)

All:

Just listened to Marci Kinter's (SGIA) excellent webinar today on the CPSC regulations that go into effect on 12/31/11. 

I'm very interested to hear from everyone on how this is going to affect your business. How are you going to implement the testing and GCC components of the regulation operationally in your shop?

Remember, after 12/31/11 you will not be permitted to legally sell printed shirts with ink or other components (zippers, buttons, etc.) for youth under 12 that isn't under 100 ppm lead, and also for toddler under 3 for anything that promotes eating or sleeping has to be certified phthalate free.

To me, it's seems obvious that it would be very beneficial from a shop operator standpoint if the ink manufacturers could supply shops with the batch certification testing documentation upon either ordering or delivery. As an industry we need to band together and flood your reps with this request so that they understand how this affects us. Testing every order is financially impossible for shops and either they will be in non-compliance or they will just simply stop printing youth. 

I'm curious to get everyone's reaction and plans on how they think that they may handle this challenge in their shops. Anyone care to share?

Thanks,

-M


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## mikelmorgan (Nov 1, 2008)

I'm curious as to who is going to enforce this law. I know very little about it other than it is going into effect. My understanding was that the manufactures were to quit making this type of ink and it would be fazed out. This is the first I've heard that at the local level we can not produce these types of garments. I know my suppliers have stopped selling this type of ink but what am I to do with what I have in my shop? And like I said, who is going to stop by my shop and inspect what we are doing? If someone stopped for that, what about all the other unsafe practices going on in shops all over the country ie plastisol down the drain, cleaning fluids and other chemicals spilled and scores of other things we know are going on in small and home based shops?


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## bluemoon (Feb 8, 2009)

my take on it after listening to the seminar is that either the manufacturers or the suppliers should have separate batches of ink that have been tested and come with a component level certificate (at a higher price though).

Shops can just go through the paperwork to get what they need to generate the certificates from it. It might take a few hours to get it done, but then it would not be an issue any more.

pierre


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## DAGuide (Oct 2, 2006)

I took away that all screen printed, heat transfers and dtg prints that use white ink (because they view it as a spot color) are required to have the testing done if you do not fall under the small batch manufacturer exemption AND they don't view the ink you are using to fall under the lead in paint testing requirements. Otherwise, you have to do the testing (final product) or you have to get the manufacturers of all the components to do the testing and provide you with the test reports. Is this the same that everyone else got out of it?

I see the biggest challenge as being the paperwork and the tracking labels (which garment decorators should already being doing, but most are not). Basically, you have to tie the tracking label on a single piece of garment back to all the component tests through the use of the General Conformity Certificate. This means that each screen print job must have a unique identifier on it (i.e. job #2) that can relate back to the inks and chemicals used (i.e. if you do anything to alter the ink or that it could come in contact with that could potential cause contamination or a be viewed as a different product than what was tested, it must be tested - bases, additives,...) by use of the General Conformity Certificate that lists all the tests used and the test results. (WOW, that is a mouth full). The traceability part (which is absolutely the responsibility of the garment decorator) is the challenging part. You have to know what batch of ink is being used, what test report is associated with that batch of ink and then create the conformity certificate for the garment for each ink used and any other components on the garments. You almost need a software system that ties into your invoicing software and your inventory software (which also includes all the inks on your shelf and has the components for each garment listed) in order to make this an automated process. 

I too would love to hear anyone's thoughts on how to make this process more simplified. Otherwise, the price of children's garments must go up.

Mark


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## bluemoon (Feb 8, 2009)

DAGuide said:


> I took away that all screen printed, heat transfers and dtg prints that use white ink (because they view it as a spot color) are required to have the testing done if you do not fall under the small batch manufacturer exemption AND they don't view the ink you are using to fall under the lead in paint testing requirements. Otherwise, you have to do the testing (final product) or you have to get the manufacturers of all the components to do the testing and provide you with the test reports. Is this the same that everyone else got out of it?
> 
> I see the biggest challenge as being the paperwork and the tracking labels (which garment decorators should already being doing, but most are not). Basically, you have to tie the tracking label on a single piece of garment back to all the component tests through the use of the General Conformity Certificate. This means that each screen print job must have a unique identifier on it (i.e. job #2) that can relate back to the inks and chemicals used (i.e. if you do anything to alter the ink or that it could come in contact with that could potential cause contamination or a be viewed as a different product than what was tested, it must be tested - bases, additives,...) by use of the General Conformity Certificate that lists all the tests used and the test results. (WOW, that is a mouth full). The traceability part (which is absolutely the responsibility of the garment decorator) is the challenging part. You have to know what batch of ink is being used, what test report is associated with that batch of ink and then create the conformity certificate for the garment for each ink used and any other components on the garments. You almost need a software system that ties into your invoicing software and your inventory software (which also includes all the inks on your shelf and has the components for each garment listed) in order to make this an automated process.
> 
> ...


a quick thought here. . . One of my other ventures is the website that will provide tracking services for the recall compliance. Right now, you can enter the lot numbers and all the info into the system and then stamp the shirts with the generated recall number. Consumers can go to the web site and check the recall status and the manufacturers can search for all the product that used a particular batch of ink.

Next step would be to incorporate some of the compliance info in there too. And if we are smart, we might even get it to generate the compliance certificates.

So in the end, yes it would be an outside solution, but since the tracking info has to be done too, might as well get everything done at once. While you would have to go into an outside system to get it done, it is really not that much more time consuming that what is already being done. There are few other possible benefits too, but that's a different conversation.

pierre


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## DAGuide (Oct 2, 2006)

Note a bad concept Pierre. Remember, you have to incorporate all the component part testing. It is cool if it is just a basic t-shirt (which is the majority of the stuff), but any prints on jeans going to be a pain because of the zipper, the fasteners,.... 

Mark


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## AtkinsonConsult (May 2, 2011)

All:

As part of the supply chain, how many folks out there have contacted their vendors and started the process of demanding that they do the batch testing and supply their customers with the information upon either the order or the delivery of the product?

There's a business opportunity here, as I see that if one zipper or ink guy DOESN'T provide the testing and certification - but another will - maybe it makes sense to buy from someone else if your company provides printing for the youth market? 

Sure, nobody wants to do these tests. And these tests aren't cheap either - $50 - $350 each from what I hear. Try selling your youth baseball team shirts with that added onto it.

My fear is that for everyone trying to do this the right way - there will be 50 guys down the street that won't. This is going to lead to an educational challenge with our clients, not to mention I may have higher prices due to this issue.

-M


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## tpitman (Jul 30, 2007)

You'll have higher prices, the guy down the street won't. The average customer doesn't care. You can explain to them 'til you're blue in the face about the law, your increased labor to affix a tag and catalog the details of the ink, the shirt, and whatnot. It'll go in one ear and out the other. After your presentation, they'll have a blank stare on their face, and the only question they'll ask is, "So how much for the shirts?"
The public hasn't been inundated with horror stories of children suffering life-threatening illness or horrible disfigurement from wearing a t-shirt. The big companies, and conscientious (or litigious-averse) small shops will dutifully adhere to the law. Everyone else will blow it off, unless the gubmint takes it upon itself to root out the scofflaws amongst us, or launches a site like "attackwatch" for competitors to rat out their serigraphic brethren.
The whole thing is overblown. As far as I know, no inks use lead, or have, for years, and the pthalate ban could stop at things like childrens' bibs. Any kid 3 and under that eats enough of an imprinted shirt to suffer any ill effect from pthalates likely has other issues far more important. Inspect goods from China, since that's where this whole thing started (and always seems to), but why punish everyone? They're too lazy to see the unintended consequences of their overreach, as usual. The EPA wanted to punish farmers for kicking up too much "dust" with their plowing . . . claiming it was a pollutant. That's the government in action for you. Pass a law, problem solved, let's go home.
You don't even want to know what I really think . . .


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## veedub3 (Mar 29, 2007)

Ha,ha,ha....Tom I would really like to know how you feel!!! OMG that made my night! I get customers like that every day.


> Any kid 3 and under that eats enough of an imprinted shirt to suffer any ill effect from pthalates likely has other issues far more important.


 ha,ha,ha.....what truth!!!!!!!!


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## charles95405 (Feb 1, 2007)

2 years ago I stopped doing any garment for 12 and under. Has not really effected my bottom line


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## Fluid (Jun 20, 2005)

mikelmorgan said:


> I'm curious as to who is going to enforce this law. I know very little about it other than it is going into effect. My understanding was that the manufactures were to quit making this type of ink and it would be fazed out. This is the first I've heard that at the local level we can not produce these types of garments. I know my suppliers have stopped selling this type of ink but what am I to do with what I have in my shop? And like I said, who is going to stop by my shop and inspect what we are doing? If someone stopped for that, what about all the other unsafe practices going on in shops all over the country ie plastisol down the drain, cleaning fluids and other chemicals spilled and scores of other things we know are going on in small and home based shops?


Honestly you would be surprised by this. Local EPA inspectors do and will eventually get by your shop. I thought the same as you did for years and then one day, guess who walked through the door. Funny thing was we were 100% up to date on everything and even then, the inspector thought she knew everything and tried to slap us with a very large amount of money for non compliance for incorrect fire safe cabinets for some of the chemicals and inks. The fine was going to be upwards of 15K until we were able to prove that what we had was in fact correct. She left to research and came back to give us the stamp of approval.

They will get by. might not be this year or the next yet they will be by. And no matter who you buy from, it is your sole responsibility to comply even though one would think it would be the manufacturers.


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## Fluid (Jun 20, 2005)

AtkinsonConsult said:


> My fear is that for everyone trying to do this the right way - there will be 50 guys down the street that won't. This is going to lead to an educational challenge with our clients, not to mention I may have higher prices due to this issue.
> 
> -M


Indeed this is going to happen. We still have people down the street cleaning their screens behind their shop or even in their back yards. It is sad yet will never end.


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## tpitman (Jul 30, 2007)

charles95405 said:


> 2 years ago I stopped doing any garment for 12 and under. Has not really effected my bottom line


I've done so little youth stuff that, frankly, it's hardly worth my time to take it in and go through the rigamarole to comply with tracking numbers, contact info, and the accompanying record-keeping. I'm conscientious about product I use in my shop, what little goes down the drain, and how I dispose of unused ink and cleaning rags. I also understand the thought behind the law, but again it places a burden on small domestic printers that is onerous in comparison to any ill effects ever likely to be suffered by a customer. What is the likelihood that a customer will read something about some ink in the paper, go dig through their brat's closet, looking for contact info and a batch number? What's the likelihood of a run of 72 shirts printed by Joe's Screenprinting and Meth Labs to be featured on the nightly news as being subject to a recall? Large shops printing hundreds of thousands for WalMart or Target, maybe. Offshore operations mixing radioactive waste to extend their inks? Definitely. Podunk operations like mine? Gimme a break. The government will put more people out of business for failure to comply with the dotted "i" and crossed "t" than for the material used in the product.


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## mpierce513 (Nov 17, 2007)

Does anyone know if any of the ink companies are going to have their ink tested and provide the component certificates? Hope they do it will save us a lot of work and money and it will be the ink company I buy my ink from. One of our tshirt suppliers has told us no one worries about this but yall so I realize 90 percent of the printers are not worried about this new law but for those of us who want to be in compliance we need to keep asking our suppliers for the certificates and if they don't provide them look for the one that does and move our business to them. I know the ink is not suppose to have lead in it but the new law still says we have to supply the certificates and they have to contain the testing labs name and phone number.


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## tpitman (Jul 30, 2007)

WM Plastics, QCM Inks and Excalibur Inks have posted theirs. I don't know about resellers like Ryonet who sell other's inks under their own labels.


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## AtkinsonConsult (May 2, 2011)

All:

Just to clarify a point here... Ink Testing Certificates have to be for every batch. That means that every time a zipper manufacturer or ink manufacturer makes a batch of product, they have to test them on an individual basis.

If these folks can't do that, then this testing will have to be performed by the screen printer. That's the problem. According to the regulation, someone has to do the testing.

Yes, its unrealistic. Yes, its unfair. Yes, tons of people won't do it. 

Avoiding all that - who has any ideas on how to implement this? I'd love to find out other people are handling this..

Thanks,

-M


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## thutch15 (Sep 8, 2008)

I just spoke with my Ink Mfg (One Stroke)... they said that they are in compliance and post their info under the compliance section of their website. However they do this based on the formula and not the batch. Anyone have any links to the actual rules from the CPSC?


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## mpierce513 (Nov 17, 2007)

I have emailed QCM about the batch testing since that is the ink I already use. I think as screen printers we all need to start pushing for this so everyone email or call their iink company and ask for it. I would think if enough people ask they will do it. I do not know how much ink they make in one batch but it would be better if they do it, I will pay more for the ink that has been tested and I will buy my ink from the company that provides this even though we really like QCM.So with that said please call or your ink company. We have to start providing this information as of 12/31/11 so we do not have a lot of time.


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## mpierce513 (Nov 17, 2007)

I have had the colors of ink we use on most of our tshirts tested and it was $55 per color and took a couple of weeks. But since it is batch testing I will have to have it retested (I guess everytime I buy it if the batch # isn't the same) which could cause a problem if you are in the middle of a job and run out of ink} so that is another reason we need the ink companies to do this. I do not know how often if you buy a gallon of ink and go back and buy another one that the batch numbers would match, does anyone know that. I know a lot of people on here said they would just not do children's but nearly all of our orders have adults and children's on it so I do not know how that would be possible without loosing the entire order.


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## mikelmorgan (Nov 1, 2008)

Why is this so hard to get information on. I would think that the EPA would be sending letters or some kind of information on this. I have received absolutely nothing from the government about this. I tried to do a google search on this and I have to dig and still can't find anything of relevance.


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## tpitman (Jul 30, 2007)

Apparently it'll be on the suppliers of the components that we add over the course of decoration of the shirts, such as ink, foil, rhinestones, and so on.
It also appears from another thread on this forum that we'll have to register as small producers to avoid paying for testing as long as we can get certified compliance reports from our sources.
Seems to me that batch testing by ink companies is going to create a logjam in production, unless I'm misunderstanding something. How may "batches" of a color or type does a manufacturer make, say in a week? If they have to get every batch of every color of every kind, this along with everyone else manufacturing stuff for children, it seems to me that things will grind to a halt.
As for now, you can get a certificate based on the stuff they use, and samples of which have been tested. Here's QCM's:


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## tpitman (Jul 30, 2007)

Here's the other thread that's currently discussing the stuff. They've posted some info with links to the government legal mumbo-jumbo . . .

http://www.t-shirtforums.com/general-t-shirt-selling-discussion/t69913.html


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## AtkinsonConsult (May 2, 2011)

Tom:

Thanks for including QCM's memo - unfortunately as I understand the ruling this won't be good enough. Either the ink manufacturers are going to have certify each and every batch of ink that is coming out of their facility on and individual per batch basis...(which I find it hard to believe they will do)...or the end user (the screen printer) is going to have to pay for the testing.

These types of certificates, MSDS sheets and other guarantees aren't good enough for the CPSC. That's the problem. It isn't just ink either...it's going to be for zippers, buttons, trim, etc...everything that can be on a shirt. Textiles (the shirts) are exempt, its the added stuff that's not.

The ink folks are going to have a hard time paying for this testing as every screen printer out there is going to mix that ink with some additive or contaminate it during their print process. The ink companies aren't going to want to pay for the testing and be held accountable when the product fails during an audit, because they can't control the production process.

That leaves the screen printers. We're holding the bag, and something dark and stinky is inside of it.

-M


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## AtkinsonConsult (May 2, 2011)

Mike:

SGIA has tons of information on this and has the webinars in a viewable file from last week. Marci Kinter has been on top of this since 2008.

SGIA - Specialty Graphic Imaging Association

-M


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## ScreenFoo (Aug 9, 2011)

Lead and other heavy metals have been banned from inks for well over a decade now. If it's still in a bucket of ink that you bought last week, is that your fault? I guess so. I think this is just like any other industry craze--take food safety--the people who are contaminating food are in the fields, being paid slave wages, but it's the local restaurant owner who faces the wrath of the public--and so the underpaid cook gets harassed for not washing their hands enough, even though they have dermatitis from overuse of antimicrobial soap.

Mike: They will not send everyone the book that would be required for this mumbo-jumbo. Section 103 is already in effect, and has been for over two years now. Also, if I'm not mistaken, this is the domain of the CPSC, not the EPA.

There is a FAQ on section 103 located at:
FAQs For Section 103: Tracking Labels for Children’s Products - Consumer Product Safety Improvement Act (CPSIA)

Here's the actual text--if the fear of the law is giving you insomnia, the actual text is all but guaranteed to cure it:
[media]http://www.gpo.gov/fdsys/pkg/BILLS-110hr4040enr/pdf/BILLS-110hr4040enr.pdf[/media]Although this is the text of the actual law, it provides very little useful information as to what you should be doing. In fact, from what I read about the initial framework, (no idea how accurate the interpretation of said info was) there were to be no raw material exceptions, and EVERY run had to be tested as printed--not as components. 

As far as suppliers testing for us, I'm not holding my breath. Last year when I was testing white inks I noted that the HMIS ratings on the bucket of XOLB-159 did not match up with their MSDS. Got another sample last month and checked the website. It's still incorrect. Isn't there a law that says the ink manufacturer has to provide accurate and up to date safety information for employees? 


Edit: I was thinking I had not even heard of an accredited lab for Pthalate testing-- Bob's (Flint54) recent post on the other thread says:

As of this date there are no laboratories that have been recognized by the CPSC for testing of phthalates. This could change at any time so as a final product manufacturer you will need to stay updated on laboratories that may be recognized at: List of Accredited Testing Laboratories .

You must test for these chemicals, at a lab that doesn't exist. WTF? At least we're not making pacifiers for a living, people.


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## DAGuide (Oct 2, 2006)

ScreenFoo said:


> Edit: I was thinking I had not even heard of an accredited lab for Pthalate testing-- Bob's (Flint54) recent post on the other thread says:
> 
> As of this date there are no laboratories that have been recognized by the CPSC for testing of phthalates. This could change at any time so as a final product manufacturer you will need to stay updated on laboratories that may be recognized at: List of Accredited Testing Laboratories .
> 
> You must test for these chemicals, at a lab that doesn't exist. WTF? At least we're not making pacifiers for a living, people.


Marci Kinter mentioned this on the first SGIA webinar, but the next day at the start of webinar #2... she corrected the statement. I believe she stated someone from one of the ink manufacturers (QCM I think) sent her an email stating otherwise. So I do believe they are out there now.

Mark


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## lilsuz (Oct 16, 2007)

On December 11th, I sent an email to QCM inks:

My Message to QCM:
Hello,
I bought a whole bunch of your XOLB inks over 5 years ago, just wondering if your inks have always been pthalate free?
Please call or email me with answer.
Thanks so much!
Sue

On Dec 12, i got this reponse from QCM:

 Sue,

You may or may not know that Rutland Plastic Technologies bought QCM Inks this past July. We would not have any records that go back more than a year. It is my understanding that they have been promoting their products as being phthalate free for some time. I pulled a quote from the web site

 "Roy Wheeldon, QCM’s chief chemist and later, President, led the technical direction of the company. Roy was an ardent environmentalist long before it became fashionable, and strongly believed in corporate and individual responsibility. Roy’s mission was not just to make the world’s best screen printing ink, but to make the world’s most environmentally friendly ink. Under his technical leadership, QCM quickly eliminated heavy metals, chlorinated organic solvents and other nasty chemicals from its chemistry. Becoming aware of the “gender bending” dangers of Ortho-Phthalate plasticisers, Roy made it QCM’s mission to also eliminate these in all QCM Plastisol formulations. Roy succeeded. All QCM plastisol inks have now been "Phthalate free" for over 10 years. We understand the chemistry and, as a consequence, our Phthalate free inks work!

QCM's commitment is to direct the development of ink technology to even higher levels of renewable and recyclable capabilities. QCM is heavily involved in research that uses the most up-to-date bio-based plasticizer technology. QCM products contain no heavy metals, which are often associated with the printing ink industry. In addition, QCM plastisol inks are noted for the absence of Cadmium, Azo, Formaldehyde, Chromium, Lead, Tin, Nickel, Tri chlorophenols, Chlorinated organic solvents, Tetra chlorophenols, Penta chlorophenols and disperse dyes. From the very beginning, the QCM plastisol raw material selection has always avoided the use of heavy metals and solvents, earning a classification as 100% Non-Toxic."

Thanks

 Tony Chapman​ Technical Service Director​ Rutland Plastic Technologies, Inc.​ 10021 Rodney Street​ Pineville, NC 28134​ 704 553 0046 Ext. 147​


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## AtkinsonConsult (May 2, 2011)

Sue:

Thank you very much for sharing, that's great info.

One of the biggest issues with following this regulation is that there are products out there already that meet all of the specifications outlined by the law, but everyone will have to do the testing anyway. It doesn't matter what the public statement is from the companies, how the MSDS sheet are worded, or if they have some testing info "once" that they are sharing.

Either the ink companies can step up and batch test when they make the huge quantities of the ink, or it's going to be left to the screen-printer to do it. Don't forget that that this also applies to other items that are used to decorate or components of garments as well - zippers, rhinestones, rhinestuds, transfers, crystals, etc.

At this point I don't think any of the ink companies have publicly stated their position on this, but it's evident that any of them that decides to handle this for the screen-printer is going to have a competitive advantage over ones that don't.

-M


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## lilsuz (Oct 16, 2007)

Marshall,
Yes, I felt that the e-mail I got back from QCM was not the answer I was looking for. I wanted to hear that they had some certification that would work for us. Not just a statement about how great their ink was. Still, we are left with no certification to show that we are in compliance. It was well written and all of that, but not really what is needed. I don't feel I can use my QCM inks for the "12 and under" group. So, I simply won't.


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## AtkinsonConsult (May 2, 2011)

Sue:

That's my point entirely. 

From the supply chain standpoint our vendors can be part of the problem, or part of the solution. Make it easier for the printer to be compliance and prove it with handling the batch testing, and provide an easy link for documentation? They will own some huge market-share. 

Sticking your hand up in the air and saying "we're good, don't worry" doesn't work.

I'm sure ink guys troll these forums too - any of you brave enough to comment? 

Also, let's look at it from their perspective...if they did the testing and provided the certification who's to say that the printer wouldn't load up the ink with contaminates in the shop? Are shops going to completely remove every possible source of contamination from the floor?

I don't think there are any easy answers, but this industry needs to figure out how we can handle this and move forward. For some shops it's easy to say "we just won't print any youth", for others like the one that I work for, that's not an option.

-M


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## lilsuz (Oct 16, 2007)

Marshall,

I'm really bothered by how this will effect garment decorating businesses as well. I really don't want to turn down any jobs that involve children's garments, but I'm a small business and cannot afford the investment it will take to be in compliance. I agree, we have to figure out as in industry what can be done. We need reasonable solutions. I can see this leading to high prices on children's garments and it would also make sense that it won't be easy for schools or other groups that order children's sports uniforms or anything else intended for children to find items that are CPSP certified. Makes me wonder too, what about Thrift Stores, Second hand stores, and non-profit organizations? Will they be around any more for the "budget concious" shopper. Or, will non-profits able to help the needy any longer?

Can we no longer sell our second hand clothing on Ebay? Out of curiosity, I ldid a search on Ebay for "CPSC" and "CPSIA" and found mostly bicycle helmets and exercise matts for sale, not much else. I also did a search for "not intended for children" and "not for children" and found about a 1/2 dozen pages of items that way. I also posted a question for a seller who was offering an item for children that mentioned nothing about "CPSC" and asked if the item was "CPSC" certified. Just curious about what kind of a reaction I would get. Will the seller do a little research and answer my question? Do they know anything about CPSC?

I walked into a local 2nd hand store that just opened near my shop the other day. The shop is offering 2nd hand Childrens toys and clothing. Stuff for Adults too. I asked him if he knew anything about CPSC (?). He did not. He was glad to know something about it, but I could see the worried look wash over his face. I told him to find out what he could about it, and I would do the same. We plan to update eachother soon on what we find out.

TTYL & Thanks for your posts!


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## mpierce513 (Nov 17, 2007)

I currently use QCM and emailed them last week about their intentions on testing their inks and had no response. I am looking for that ink company that decides to do the testing and will change all my ink to that company. I realize their has been a law about lead in the ink for years and there are a couple of companies that say their inks are in compliance but they are not offiering the certificate with the lab (that has been approved on it) name on it along with the batch #. But we need the certificate and we need it tested by a lab that has been approved. I know the ink companies are probably saying why should we test our inks with one of their labs we know it is in compliance, well we are saying the same thing, it is stupid and we do not want to mess with it either but the law says we must do it. I know the inks will probably go up some but I would rather pay a little more than have to go to the trouble of having to do it myself. I know a bunch of people are saying they will just not do youth shirts anymore but I also know that 85% of the jobs have some youth shirts on them so that is nearly impossible without losing the job. I know the other half of the screenprinters are just saying I am not going to do it, well if they want to catch you they will, it would not be that difficult. Listen up ink companies if you are the one company that decides to take this task on and you start advertising it, you will be the leader in the industry and you will have a bunch of new customers. But you need to speak up because we are going to have to start buying larger containers of ink and sending in your test samples for the testing within a few days to have them ready for the first of the year.


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## lilsuz (Oct 16, 2007)

*Dear Ink Manufacturers:*

Dear Ink Manufacturers:

If you want to sell more ink, please provide the documentation we need to be compliant with CPSC / CPSIA for printing garments for children under 13 years old.

Do you want our business? If so, please post your intentions here.

Thank you!


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## Pvasquez (Feb 19, 2011)

*Re: Dear Ink Manufacturers:*



lilsuz said:


> Dear Ink Manufacturers:
> 
> If you want to sell more ink, please provide the documentation we need to be compliant with CPSC / CPSIA for printing garments for children under 13 years old.
> 
> ...


Many of you that are currently dealing with this know that this is usually required by the big chain stores and your customer is responsible of testing goods before they actually hit the shelves not you since they are the (seller) you just need to make sure your using compliant products, but regarding the concern at a local level just make sure your using compliant products and most of the ink manufactures are not going to intentionally sell you something that is not compliant but they have no real control on how you use the product i.e. what additives your mixing in them using same manufacture of ink or intermixing different manufactures which is very common using one manufactures ink mixing system and using some other white as the base due to price etc. if it fails a test who is the responsible party?

Here are the Wilflex Results I usually send these to my customers customer and for the last three years there has been no issues with the exception that sometimes they want an updated test results as they do expire and/or clarification on a specific product make sure they are covered. If you are the manufacture of actual designs and are looking to get your product on these big chain stores then yes YOU are responsible for test results and batch testing on the printed good. Hope this helps. I am no Pro but I will say that I have customers printing an easy million goods per month and these are a mixed of youth and adult but they follow the rule for all goods just as if it where for youth because the stores are demanding this.


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## mpierce513 (Nov 17, 2007)

From what i understand we, the screen printers HAVE to have a certificate saying that ink has been tested, by a lab that has been approved, for each batch # of ink or we have to do it so does Wilflex test each batch and test it with an approved lab and will you provide me a certificate stating that if so I will place an order tomorrow for their compliant ink. And I am sure their will be many more screen printers who will do the same. I do not know how much ink is made per batch does anyone else know.....


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## Pvasquez (Feb 19, 2011)

mpierce513 said:


> From what i understand we, the screen printers HAVE to have a certificate saying that ink has been tested, by a lab that has been approved, for each batch # of ink or we have to do it so does Wilflex test each batch and test it with an approved lab and will you provide me a certificate stating that if so I will place an order tomorrow for their compliant ink. And I am sure their will be many more screen printers who will do the same. I do not know how much ink is made per batch does anyone else know.....


Tell you what I will contact Wilflex in the am and follow up on clarification of this rule and make sure there are no extensions in place I will post those findings but please understand that they tried to make this happen in the past but could not because what is asked can't be done due to that most of these labs are in Europe and we are typically behind by several years. If there is an extension in place or not there will be before the actual due date. If you want actual batch test results I will also find out if this is something we can provide as a distributor you have a good point.


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## mpierce513 (Nov 17, 2007)

Thank you....it would be muchly appreciated by all of us screenprinters. Hopefully another extension will be in place before our deadline of Dec. 31. But if not, if Wilflex offers what we need that will be the ink company we go with because we plan on following this rule even though we do not agree with it, let me restate that I believe in controlling the lead in the items for children, what I do not believe in is the batch testing (if yall know the ink does not contain lead or phthalates why the heck do we have to have every batch tested).


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## AtkinsonConsult (May 2, 2011)

Pablo:

Thanks for your information, but it's not accurate or up to date with the regulation that goes into effect on 12/31/11. 

True, Wilflex (and all the other manufacturers really) have provided the information on their product regarding the chemistry. Nobody is doubting that.

The issue is that now, the government is asking that this be repeatedly proven for every batch and order shipping out the door. The CPSC has stated that the testing from the manufacturers is voluntary, but the end user (the screenprinter) is ultimately responsible to make sure that this batch test happens, and has the documentation available on the General Conformity Certificate that has to ship with the order.

This means that someone is testing...either the manufacturers or the printers.

Testing labs are all over the United States, I pulled a list from the CPSC website. I'm in Wisconsin and I located a half dozen within a day's ground ship from me, and one actually in Milwaukee. Finding the lab isn't the problem. It's forking over between $25 (lead) to $150 (phthalates) per test (what I was quoted last week) for the testing if we have to do it on our end.

This could add significant cost to that youth order...to the point that orders could be lost to someone that isn't testing. Shops just can't absorb this cost.

There are plenty of shops around the country that either don't care or aren't in tune to this challenge. The consumer is unaware too.

All in all, it's a mess.

-M


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## Pvasquez (Feb 19, 2011)

AtkinsonConsult said:


> Pablo:
> 
> Thanks for your information, but it's not accurate or up to date with the regulation that goes into effect on 12/31/11.


I don't doubt that there are labs everywhere it was the approved labs and I'm sorry they must have edited the list since last I looked at it which at the time was worthless lol. I'm sure it will be extended and just make sure your using compliant products which I'm sure you are. Your right regarding which shops will actually do what needs to get done etc. but really how many actually have Garment registration license and without one it's a max penalty of 100$ per employee but let's not go there right? Is anyone actually putting into practice what is being asked? If this was to actually to be taking place everything that is on shelves should have a conformity code permanently on the goods because after the 1st those goods would not be able to be sold correct? Why are our current customers not stressing this at a local level and like I said we are talking about millions of youth goods. Licensed products etc.

Something I would like to add if you read the rule it's the batch ( of goods produced ) not the batch of ink so you can still use the eccopassport from say Wilflex but you would still need a test done that has your info so as a distributor doing actual batch tests does nothing. Again I want to stress that it can be done but an example would be to send a few ink to a lab along with conformity statements so you can be issued a conformity statement of your very own now the next thing is you will need to print this number on the garment. Somewhere inside so it is permanent until it too expires then get another test it would be fudging it a bit but technically you would be compliant as long as you don't change your products or stick to one manufacture of inks. If your always testing other products then you run the risk of cross contamination but I'm sure you would be fine one test every so often or different numbers for different product used i.e. Wilflex Or other manufactures.


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## Pvasquez (Feb 19, 2011)

Still looking into this but it's not looking good. I understand everyone's concerns seeing now what a nightmare this can potentially be for the average screen printer, on another note looks like you also need to register with CPSC which means who else will be knocking on the door not that anyone has anything to hide but I wonder what kind of fees this will cost. Will post more finding as I get them. As of now this will take into effect on 12/31/2011


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## tpitman (Jul 30, 2007)

I think you have to register as a small-time (or whatever they call it) shop to avoid doing the testing yourself, as long as you have certification that tests have been run on the components you use from the manufacturer. Apparently, they're not obliged to test, which would put it on the printer, or last in line in the production process of the garment. I guess that would give them the opportunity to come snooping around to check the ink on your shelf, or ask for your records of youth printing. Doesn't mean you can't keep non-compliant ink on the shelf. Apparently you have to send along a sheet explaining compliance with the batch numbers, but I don't think you have to print those on the shirt, just your contact info and a job reference number, which could or could not be any batch number, and you have to have contact info for the person or business you're selling to so you could contact them in the case of a recall on any batch number of any component.
From several discussions on different boards, this is what I'm getting, and it's by no means accurate. Could be all bass-ackwards.
Marshall summed it up nicely . . . "It's a mess."


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## DAGuide (Oct 2, 2006)

Here is what I would like to know. During the SGIA webinar on CPSIA, Marci Kinter stated that you would have to test the base colors... but not the mixture of all colors. So the two many questions would be:
1. How many base colors are there in screen printing?
2. How often does a screen print manufacturer make batches of these base colors?

Several years back (around 2004), I got the opportunity to walk through Nazdar's facility in Kansas where they make several different types of ink and other chemicals. I believe some of them were plastisol inks... but I am not sure. The containers making the inks were very large...but have no clue how many gallons of ink they would hold or make. If a screen print ink manufacturer makes 10 batches each month (one batch every 3 days) of each base color (multiple that times the number of base colors)... then I can see how this can be a pain for the screen print ink manufacturer. However, if the number of batches per a month is less, then I think there is a greater likelihood of getting the batch testing done. Maybe some of the ink manufacturers will do testing on just a limited number of colors (white, black, red, yellow, green and blue) and make a label that identifies it as being tested like we have for the high efficient laundry detergent.

I guess the other thing is how "batch" is defined. If they are use 12 containers to make the same formula at one time... is this one batch or 12 batches? Definitely things that need be considered. Since the screen printers don't know the difference from one batch to another, they would have to test ink each time it was ordered. (This was one of my questions during the webinars that Marci was nice enough to answer via email a day later). This would also require the screen printer to build in time to get the ink tested before the garments are printed and sold. That is why I think the only good solution is for the ink manufacturers to do the testing. However, they sell ink at such low margins... the price is definitely going to go up to cover the testing and all the paperwork. Thus why I expect a limited number of colors to get tested if at all.

DTG printing is a completely different story. CMYK inks are exempted, but the white ink and pretreat fluid follows the sames hurdles as screen printing from I got from the two SGIA webinars. This means all the companies that sell relabeled Dupont white ink will have to do their batch testing or they would have to get Dupont to do the batch testing and release test results that openly show they are relabeling the ink. The latter I think is more likely in most cases, but there is still a huge pain for all the paperwork tracking and matching it up to each bottle of ink or cartridge. Many distributors package (bottle or put into cartridges) the ink in-house or pay another company to do it. This would require each bottle / cartridge to have the batch number on it. If you want to get particular, one could argue if using bulk white ink... you could be mixing two different batches together and that would either (best case) require listing both batch test results in your conformity certificate or (worse case) you would have to do a new test of the combined ink as you could have contamination. 

Tracking all of this is going to be such a challenge no matter which decorating process you use. I am expecting to see more children clothing become more basic (no zippers, buttons,...) and less colors in order to minimizing the price increase to the customers. Time will tell real soon I guess.

Mark


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## mpierce513 (Nov 17, 2007)

I do not think you have to register either unless you want to register you want to take the small batch exemption which you have to qualify for. Come on some ink company have mercy on us screen printers and get your inks tested. It is nonsense for us screenprinters having to test,if we do there could be 100's of test ran on one batch of ink. We realize you will probably have to go up on the price a little to compensate the cost but it will sure save the screenprinters in the end. The last batch of ink I got tested cost me $55 per color to test for lead. If you do not get a large container of ink and only buy gallons or five gallons you are testing everytime you get a new container. I looked at my shelves and out of all the gallons of ink we have up ther only two gallons batch # match.


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## lilsuz (Oct 16, 2007)

*Re: Dear Ink Manufacturers:*



Pvasquez said:


> ....I am no Pro but I will say that I have customers printing an easy million goods per month and these are a mixed of youth and adult but they follow the rule for all goods just as if it where for youth because the stores are demanding this.


Pablo,
Thank you for responding to our concerns. It is good to know somebody selling us inks is also concerned. Again, hopefully the ink manufacturers will give some input and let us know if they have a gameplan. By the way, I noticed that the first document you posted was good only for 9 months. Are these certificates typically for just a 9 month period?


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## DAGuide (Oct 2, 2006)

*Re: Dear Ink Manufacturers:*



lilsuz said:


> Are these certificates typically for just a 9 month period?


If you are doing component testing, the certificates can only last as long as a batch of ink last. Once a new batch of ink is made, a new certificate must be made as well. I doubt a batch of ink last 9 months or the cost of doing the test would not be that much.

Mark


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## Pvasquez (Feb 19, 2011)

lilsuz said:


> Pablo,
> Thank you for responding to our concerns. It is good to know somebody selling us inks is also concerned. Again, hopefully the ink manufacturers will give some input and let us know if they have a gameplan. By the way, I noticed that the first document you posted was good only for 9 months. Are these certificates typically for just a 9 month period?


I'm trying to get the most info on this but I still think that if you do one test and get certification then you should in fact be able to use that certification for the allowed amount of time Technically you would be in compliance if you don't change the type of ink. IMO that's the loop hole. Besides as a consumer I looked at the finish product it has a permanent label but the reality it means nothing


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## tpitman (Jul 30, 2007)

The problem with the law is it was written to cover a wide spectrum of products. From what I'd read a couple of years ago, originally it applied to smaller dirt bikes and ATVs designed for youths . . .because the batteries have lead in them. Trying to ascertain the real meaning if the law as now applied, and as it will apparently now be enforced, is like reading tea leaves, and if you've ever tried calling the IRS to get "help", you know the "public servant" on the other end of the line is reading the same thing you are, and usually knows less than you do, plus they don't absolve you of any fault for following the advice they give you.


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## Pvasquez (Feb 19, 2011)

I can't even find a list of CPSIA accredited labs does anyone have a list they would like to share? How about the OP? You mentioned that you had accredited labs around you.


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## Pvasquez (Feb 19, 2011)

Well I'm sure most of you got the SGIA e-mail today. 100K fine if not compliant? and there is a link for the accredited labs on this.


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## mikelmorgan (Nov 1, 2008)

A “children’s toy” means a product intended for a child 12 years of age or younger for use when playing, and
a “child-care article” means a product that a child THREE YEARS OF AGE and younger would use for sleeping,
feeding, sucking or teething.
Please note: Wearing apparel falls under the definition of a child-care article if it is intended to facilitate eating
and sleeping.

I can give up the 3 and under market but not the 12 and under market. If I'm reading this correctly it does not apply to ages 4-12. As far as garments are concerned.


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## jean518 (Sep 23, 2009)

mikelmorgan said:


> A “children’s toy” means a product intended for a child 12 years of age or younger for use when playing, and
> a “child-care article” means a product that a child THREE YEARS OF AGE and younger would use for sleeping,
> feeding, sucking or teething.
> Please note: Wearing apparel falls under the definition of a child-care article if it is intended to facilitate eating
> ...


Me too on your interpretation. I too can give up the under 4 with no problem.


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## Pvasquez (Feb 19, 2011)

mikelmorgan said:


> A “children’s toy” means a product intended for a child 12 years of age or younger for use when playing, and
> a “child-care article” means a product that a child THREE YEARS OF AGE and younger would use for sleeping,
> feeding, sucking or teething.
> Please note: Wearing apparel falls under the definition of a child-care article if it is intended to facilitate eating
> ...


Unfortunately they are viewing t-shirts or any apparel for 12 or younger as a Toy because they might not be playing with an actual toy but be playing in it in general so it applies to all garments for the intended user of 12 and under.


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## westmama (Feb 22, 2010)

Okay so here's what I've been doing... from what I understood last year. 

I have labels made for my t-shirts.

It states my contact info, where it's made, and for me a batch number of what I print. 

So for example I code my ink when it arrives. When I print a size run of something or even a special order I code it with the ink code I created and a date code-- I go by monthly. (p.s. I use a permanent fabric pen, also tested). 

I have a simple journal that I just note the the ink batches I've used. 

I am a super small shop and it's is really quite simple, but now I worried this is wrong.


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## tpitman (Jul 30, 2007)

westmama said:


> Okay so here's what I've been doing... from what I understood last year.
> 
> I have labels made for my t-shirts.
> 
> ...


From what I understand, in addition to what you've been doing, assuming the ink you're using is from a batch that has been tested by the manufacturer, you'll need a certificate from them showing that ink batch number has been in compliance, you'll need to send a copy of the certificate, or make up a certificate of your own with the info about the batch of ink being in compliance and send it along with the job to your customer, and you'll have to keep contact info of the customer so that you could contact them in the case of a recall. If the ink batch has not been tested by the manufacturer, then you'd be responsible for having the test done and the info passed along as noted above.
That's my understanding. Not necessarily factual.


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## jean518 (Sep 23, 2009)

I do not screen print. I use apparel vinyl, rhinestones, rhinestuds, domes, etc. If mom/caregiver of a child chooses to wear a rhinestone shirt, we all know that shirt becomes a toy by the above definition. It is not designed for the child to play with. So by that definition, mom/caregiver cannot wear anything that has not been certified. So those of you who think you are not affected because you do not do things for kids, think again. If mom/caregiver cannot wear anything not certified safe, you may well lose business. I have seen many day care facilities that the caregivers wear a shirt that is screen printed with day care logo. 

If I understand correctly, rhinestuds are not an issue but rhinestones can be. I use rhinestuds on things for kids under 4 for sure. Little girls like bling also. There again, what about mom/caregiver or anyone who may be holding the child? Grandma can't hold her grandchild if what she is wearing has not been certified safe? What about jewelry? What child/grandchild does not immediately grab at any jewelry first? Ever had an earring pulled out of your ear or a necklace ripped off your neck? It goes straight to the mouth of the child.


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## AtkinsonConsult (May 2, 2011)

All:

Don't know if this is factual or not, but I heard yesterday that Kornit will be supplying batch testing information on their inks starting in early January. My information is not from Kornit, but from someone that is well connected and that I trust.

To my knowledge this makes them the first supply chain partner to "see the light" and come out with a program to help their customers deal with this issue. A lot of these manufacturers are in the wait and see mode, instead of launching their own program, so I'm taking this move by Kornit (we have two of their DTG printers) as a very good omen for more and better things to come.

I'll post more when I have any info.

Thanks everyone for your posts on this forum regarding this topic. It's important that we stay informed as a group, and stick together and lobby our supply chain to help us on this challenge.

-M


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## headfirst (Jun 29, 2011)

I just tried Nazdar's tech support hotline. The tech support rep said 1) I was the first person to ever ask about this and 2) "batch testing certificates for all inks? That sounds a little far fetched. I think someone is misinterpreting this"

I'm highly doubtful that I'm the first person to ask about this and I'm more confused now than ever about this... 

I'm going to call PolyOne now and see what they have to say.


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## mikelmorgan (Nov 1, 2008)

Pvasquez said:


> Unfortunately they are viewing t-shirts or any apparel for 12 or younger as a Toy because they might not be playing with an actual toy but be playing in it in general so it applies to all garments for the intended user of 12 and under.


I'm confused. I got this information from the fact sheet that SGIA posted. That Pablo posted. I called my ink salesman before I saw this information and was told that the law did not effect ages above three. Nike and some of the bigger players are taking all the way to 12 but under three is what the regulation was intended for. Who has a clear definition of what this effects, with reading 2,000 pages and need a lawyer to explain.


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## tpitman (Jul 30, 2007)

jean518 said:


> I do not screen print. I use apparel vinyl, rhinestones, rhinestuds, domes, etc. If mom/caregiver of a child chooses to wear a rhinestone shirt, we all know that shirt becomes a toy by the above definition. It is not designed for the child to play with. So by that definition, mom/caregiver cannot wear anything that has not been certified. So those of you who think you are not affected because you do not do things for kids, think again. If mom/caregiver cannot wear anything not certified safe, you may well lose business. I have seen many day care facilities that the caregivers wear a shirt that is screen printed with day care logo.
> 
> If I understand correctly, rhinestuds are not an issue but rhinestones can be. I use rhinestuds on things for kids under 4 for sure. Little girls like bling also. There again, what about mom/caregiver or anyone who may be holding the child? Grandma can't hold her grandchild if what she is wearing has not been certified safe? What about jewelry? What child/grandchild does not immediately grab at any jewelry first? Ever had an earring pulled out of your ear or a necklace ripped off your neck? It goes straight to the mouth of the child.


No. The law is specific that it applies only to items _designed for and marketed to children_. A decorated adult size t-shirt is exempt. A decorated youth-sized t-shirt ordered by a high-school co-ed who likes to wear tight t-shirts may not be. There's nothing in the law that I'm aware of that specifies caregiver's clothing or accessories meet compliance.
Sewn t-shirts have been exempted. Any decorations subsequently applied have to be compliant. Lead content must be determined for children 12 and under. Certain phtalates for children 3 and under.


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## DAGuide (Oct 2, 2006)

mikelmorgan said:


> I'm confused. I got this information from the fact sheet that SGIA posted. That Pablo posted. I called my ink salesman before I saw this information and was told that the law did not effect ages above three. Nike and some of the bigger players are taking all the way to 12 but under three is what the regulation was intended for. Who has a clear definition of what this effects, with reading 2,000 pages and need a lawyer to explain.


If my memory is correct regarding what was said on the SGIA webinar, there is an exemption for one of the two tests (i.e. lead or phthalates) for children clothing between the ages of 4-12. However, you still have to do the testing for the other one.

Mark

EDITED: Just read Tom's post above and that is my understanding as well.


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## DAGuide (Oct 2, 2006)

tpitman said:


> No. The law is specific that it applies only to items _designed for and marketed to children_. A decorated adult size t-shirt is exempt. A decorated youth-sized t-shirt ordered by a high-school co-ed who likes to wear tight t-shirts may not be.


Tom,

I am not sure if all Adult shirts are exempted. There are several factors used because as you stated the rule above... designed for and *marketed to children*. This means if the apparel catalog has what looks like to be a child 12 and under modeling the garment, then the CPSC could state that an adult size shirt (X-Small and Small sizes most likely) could fall under this rule and would need to be tested. For example, some uniforms (i.e. hockey and football) are designed to have pads under them and thus are larger in size. The garment decorator most likely can't simply state it is an Adult uniform if (s)he knows that it is going to a sports team that could have children 12 and under on it. 

Since there is a current trend for children to wear larger size clothes, it is likely that the CPSC is going to use the legislative intent to say that a reasonable garment decorator either would ask or should ask what the garments are going to be used for (i.e. make sure the correct type of garment and ink is used,...) and thus should know in most cases (but not all) the age range of the potential user. There should be some flexibility, but I don't think that a flat rule that any Adult size garment is exempted is correct based on my research. I know I have been instructing my clients to start asking because lack of knowledge is almost never a good legal defense.

Would love to hear other people's opinions on this.

Mark


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## tpitman (Jul 30, 2007)

I would agree. If a pre-school or elementary school was ordering Adult Large shirts to be used as smocks for finger painting, compliance would be well-advised, although apparently not required. There are going to be instances where items that cross the youth-adult border fall into a kind of "legal compliance penumbra".

I think the whole thing has come down to who is responsible for the testing, and if by component suppliers, what kind of documentation are we to receive from them and pass along to our customers to meet compliance.


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## lilsuz (Oct 16, 2007)

Marshall, that is good news about Kornit. We will all have to keep a watch on that.

There are lots of interesting posts here and it does prove that it is so easy to read all sorts of things into the rules they expect us to follow. The fines for breaking the rules are huge.

Two of my bigger garment suppliers I have contacted to ask if they knew anything about the new rules and compliance and have not gotten response from either. One of them I communicated with over the phone first and they told me they knew absolutely nothing and suggested I email them and which department to send it to. So far, I've gotten no response. Not good, so I don't plan on getting any more garments from them if they include buttons, zippers, or are intended for children in the 12 and under age bracket.


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## westmama (Feb 22, 2010)

What if the ink you use does not use PVC, philates, solvents and the MSDS states as much. 

Would that count?

Also I posted a new thread, but was wondering about the stipulation that said printing inks were exempt.



> "In addition, as discussed in part D.13 of this preamble, we have found that certain after-treatments, including screen printing, may use leaded pigments. The commenters state that screen printing inks use four major types of ink systems: UV inks, water-based ink, plastisols, and the solvent-based ink systems. The Commission cannot determine that all screen printing inks do not contain lead
> 
> below the lead content limits. Plastisol inks are made with PVC, and, as stated earlier in part D of this preamble, PVC may contain lead. As discussed i~ part D of this preamble, the CommlSSlon will not ma~e deteYminations for any materials that have been found to contain lead.
> 
> ...


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## DAGuide (Oct 2, 2006)

westmama said:


> What if the ink you use does not use PVC, philates, solvents and the MSDS states as much.
> 
> Would that count?
> 
> Also I posted a new thread, but was wondering about the stipulation that said printing inks were exempt.


According to the SGIA webinar, you are going to have to get your inks tested if they are not digital CMYK inks (i.e. any screen print inks) and the MSDS sheet is going to work because they never get as detail as what the testing requirements are.

If you are member of SGIA, I would suggest watching the recorded version of the CPSIA webinars (2 parts). If you are not a member, you might want to consider becoming one.

Mark


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## lilsuz (Oct 16, 2007)

Hey Mark, you have a spelling error on your website. It reads "The perfect Tansfers Tool" and of course "transfers" is spelled wrong. I noticed this quite a while ago and should have told you then.


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## bluemoon (Feb 8, 2009)

doe anybody have the web site link or the phone number to register as the small batch manufacturer?

pierre


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## Tj Ryonet Tech (Jul 28, 2008)

SaferProducts.gov | Small Batch Manufacturers

Here is where you go!


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## American logoZ (Sep 16, 2009)

Tshirts & sweatshirts without grommets, zippers, etc are exempt?

Thread (embroidery) is exempt?

Must our gcc's include exempt components? 

Last question...
Any apparel vinyl mfg's offering component testing (ie, certified compliant vinyl)?


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