| CONSUMER PRODUCTS AND THE NEW CHEMICALS FOCUS: A TECHNICAL PERSPECTIVE |
| Author: Joe Ritz and Chris Gunning |
The Consumer Product Safety Improvement Act of 2008 (CPSIA) requires that children’s products and toys be tested by laboratories accepted by the US Consumer Product Safety Commission (CPSC).
One of the requirements for CPSC acceptance is that testing laboratories be accredited to the requirements of ISO/IEC 17025 by an Accreditation Body that is a full member signatory to the International Laboratory
Accreditation Cooperation (ILAC) Mutual Recognition Arrangement (MRA). The purpose of the ILAC MRA is to develop a global network of accredited testing, calibration, and inspection facilities that can be relied
on to provide accurate data and results; therefore, it was imperative that the CPSIA specifically mandate ISO/IEC 17025 accredited testing. Accepting results from accredited testing labs provides assurance of the
safety of children worldwide.
Many children’s toys are made of polyvinyl chloride (PVC), a polymer made softer and more flexible by the
addition of plasticizers, most commonly, phthalates. However, this causes a dilemma when it involves the
safety of children; studies have shown that phthalates are detrimental and prolonged exposure to them
could lead to critical health issues, including carcinogenicity, birth defects, respiratory difficulties,
and disruptions to the endocrine system. Three types of phthalates have been permanently banned, and
three others banned on an interim basis, from toys and other juvenile products upon the passage of the
CPSIA. This legislation also required a Chronic Hazard Advisory Panel (CHAP) to study the health effects of
other phthalates in consumer products.
The CPSIA authorized the CHAP to issue their findings in a final report on Phthalates and Phthalate
Alternatives, which was released on July 18, 2014. The results are quite alarming: the CHAP recommended
to maintain the permanent ban on three phthalates; to make one of the interim bans
permanent; and to ban five (four permanent and one interim) of the other 14 phthalates currently not
banned but that are used in toys and children’s products. More importantly, however, for a majority
of the 20 phthalates, the CHAP recommended that the US agencies responsible for dealing with exposure
from food, pharmaceuticals, and other products conduct necessary risk assessments. Therefore, if the
recommendations of the CHAP are acted upon, it seems certain the CPSC may either promulgate
additional, or augment current, phthalate testing product safety rules. Likewise, other US agencies such
as the Food and Drug Administration (FDA) may amend their current practice of using accredited
testing laboratories, and enact legislation similar to the CPSIA that requires ISO/IEC 17025 accredited
third party testing of food and pharmaceuticals for phthalate content.
In addition to phthalate testing, there is currently an increased focus on chemical and environmental
hazards associated with certain consumer products. Found in many types of consumer products including
electronic components, biomedical supplies, food packaging, sunscreen, cosmetics, toys, and clothing,
nanoparticles and their potential adverse effects on human health are being examined, particularly their
ability to pass through cell membranes. The ASTM International (ASTM) technical committee on
nanotechnology has published four active standards related to the environmental, health, and safety
concerns of nanoparticles. Likewise, the same committee has proposed a work item to develop
a guide on available methods, their principles of operation, advantages, and limitations for detection
and characterization of silver nanomaterials in textiles.
The CPSC has also adopted an Underwriters Laboratories (UL) standard on portable generators as
a voluntary product safety standard. One can speculate that this voluntary standard, which addresses both
electrical safety and the reduction of carbon monoxide (CO) poisoning associated with these products, may be
incorporated into a final product safety rule, requiring accredited third-party testing, in the near future.
According to the 2014 Midyear Report on Voluntary Standards Activities, dated June 16, 2014, other
CPSC voluntary standards linked to chemical and environmental hazards that may become mandatory
product safety testing include: ozone generation of air cleaners; volatile organic compound (VOC)
emissions from building products and furnishings; and, sulfur gas emissions from drywall and other
gypsum products.
The use of flame retardants in upholstered furniture to prevent serious burns and/or death have also been
studied for potential hazardous effects. Through the Design for the Environment Program, on June 12,
2014, the US Environmental Protection Agency (EPA) posted for public comment a draft update of a
previous alternatives assessment on flame retardants used in flexible polyurethane foam. This very thorough,
840-page report evaluates health issues such as: carcinogenicity; reproductive and developmental
toxicity; skin and respiratory sensitization; and eye and dermal irritation. Once the final report is
published after the comment period, it is not readily apparent if any of the EPA’s recommendations will
be drafted into consumer product legislation that stipulates accredited testing. However, it is clear that
the adverse environmental effects of chemicals on human health are being evaluated and addressed.
In summary, the focus on the chemical and environmental hazards of consumer products has been intensified.
This is made evident through recent evaluations of and reports on phthalates, nanoparticles, noxious
emissions, and flame retardants. The importance of testing results related to these issues warrants the
use of accredited third-party testing. Therefore, the relevance of testing laboratories accredited to ISO/IEC
17025, and how they play a significant role in the context of toxicity evaluations on consumer products,
will continue to be further realized. Not only does the ILAC MRA support international trade by promoting
international confidence and acceptance of accredited laboratory and inspection results, it ensures that
consumer products can be tested once and accepted everywhere. After all, consumer safety is a global
enterprise.
Joe Ritz is a Senior Accreditation Officer at the American Association for Laboratory Accreditation
(A2LA) where he facilitates the assessment process for new and renewal laboratories in the Mechanical,
Chemical, Electrical, Thermal, and Acoustics/Vibration fields of testing. Mr. Ritz, an alum of the Center for
Supply Chain Management Studies, John Cook School of Business, Saint Louis University, Advanced Product
Safety Management course, is also the point of contact for the A2LA CPSC Laboratory Accreditation
Program.
Chris Gunning is the Program Manager for Environmental Sciences at A2LA. He serves as the
main point of contact for the Environmental discipline, which includes the Department of Defense
Environmental Laboratory Accreditation Program (DoD ELAP), Wyoming Storage Tank Remediation
Testing Laboratory Accreditation Program, Kentucky Underground Storage Tank Testing Laboratory
Accreditation Program, and US EPA Environmental Lead Laboratory Accreditation Program (NLLAP).
Mr. Gunning also provides ISO/IEC 17025 training for A2LA both internally and publicly. |
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