THE CONSUMER PRODUCT SAFETY iMPROVEMENT ACT (CPSIA)

The Consumer Product Safety Improvement Act of 2008 was signed into US law on August 14, 2008

Signed into law in 2008 by President Bush

Major changes in safety regulations provides for forced recalls, import seizures and significant fines, add chemical safety provisions for lead (Pb) content, and requires certification of product safety test (third-party) for importation.

Notice Proposed Rulemaking (NPR) - Cost Burden Reduction

Cost Burden Reduction (CBR) is critical for a successful execution of CPSIA. First-party testing is encouraged, and X-Ray Fluorescence (XRF) is recognized as sufficient for first-party "test program". Use of XRF in first-party test program allows for reduction of third-party test frequency.  

Updated CPSIA is signed into law by Barack Obama (2012)

Adds a ban on Orthophthalates (OP). CPSC commissions a study of specific toxicity of phthalates (CHAP Study, 2015). Several chemicals are added and some are added temporarily. At that time, there was no first -party appropriate test method recognized  

Direction from Congress: OP cost burden reduction is a priority

Recognizes XRF as a successful measure for CBR; must develop similar soltution for OP. Engages Actus Analytical, Inc. to develop OP first-party test. Actus and CSPC agree that Fourier Transform Infrared Spectroscopy (FTIR) has the best potential, but need significant development of commercially available instruments. 

Actus Develops FTIR for OP Detection and Quantification

This is a legitimate, first-party test for OP. Development began in 2015, and was sucessfuly completed in early 2018. A specification is published and an FTIR for first-party testing is now available for compliance with CPSIA, Prop 65, RoHS 3 (10), etc. 

CPSC Deploys Actus Analytical/Agilent 4500a FTIR

Three ports are chosen and a highly successful field-trial is completed in Summer 2018.

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