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Product Safety Professional Certificate Program
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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