On Site at a Testing Lab
Counselor Finds Out What It Takes To Be Compliant
When you need to know a product is safe so you can be a superhero for clients, who do you turn to? Independent organizations like SGS. Counselor visits a testing lab to find out just what it takes to be compliant.
It's a dream come true for young eyes. A staggering collection of toys – scooters, trampolines, tiny tractors and more – stocked in what can only be described as a fantasy playroom sprung to life. Except there are no children in this room – just techs in lab coats. In fact, no kids are allowed. "Only if they're dummies," jokes one of the test engineers, referring to the crash-test variety.
The room is the Toys and Juvenile Products Laboratory, housed within the U.S. headquarters of the SGS Consumer Testing Services offices. If an outsider didn't know any better, he would hazard these professionals are scientifically proving the concept of "fun." In reality, they are performing a battery of physical tests to simulate the destructive hands of a child. Tactile accessibility probes poke in every corner and opening. Items are placed in small cylinders, designed to replicate tiny throat cavities. Toys are dropped, twisted, pulled and tipped, with the results dutifully written down after each step. Safety is the goal here. SGS test engineers are trying to ensure that each toy complies with ASTM F963-11, the new standard enforced by the Consumer Product Safety Commission.
If there's any group that could take the fun out of toys, it's the CPSC. The governing body had good intentions when it instituted the Consumer Product Safety Improvement Act (CPSIA) in 2008. Children's safety had to be safeguarded, after all, from lead paint, magnets and other dangers in toys and children's products. But the implementation of those regulations was broad, messy and subject to much (OK, very much) interpretation. "Initially, there was chaos, because the language was not crystal clear," says Piyush Shah, director of technical support – hardlines for SGS.
In the subsequent years, the CPSC has clarified its guidelines and delayed various CPSIA deadlines for compliance. During that period, ad specialty companies have become more comfortable with the regulatory landscape; in a Counselor survey administered last fall, seven of 10 respondents said product safety and testing was either important or very important to them "right now."
And yet, despite that, nearly 60% admitted to having little or no knowledge of current regulations. The confusion is typical with product safety. Distributors inevitably have questions: Why do I need to comply? Is this a children's product? What should I test for? What do these results mean? Who can help?
For all those questions, there are places you can turn to. Places like SGS, which Counselor staff toured recently, in an effort to uncover exactly what goes on when a promotional product is tested.
Independent and Certified
There is little to suggest that the nondescript building in this New Jersey industrial park belongs to a global juggernaut. But then again, that's typical of a corporation that often performs its work outside of the public view. Headquartered in Switzerland, SGS is a multinational company, boasting over 70,000 employees and 1,250 offices and labs in more than 140 countries. The corporation offers independent inspection, certification and verification for hundreds of industries. Testing is foremost among that, and it serves as the specific focus of the consumer testing offices in Fairfield, NJ. Those services run the gamut: examining typical promotional products, of course, along with more unusual duties, such as simulating cross-country drives inside an 18-wheeler to test freight packaging integrity.
The role of organizations like SGS – independent, third-party labs that offer unimpeachable proof of compliance – is crucial. Many suppliers use them for their audits and testing. Moreover, very few distributors have the means to conduct their own testing. By utilizing places like SGS, distributors can take additional measures to avoid exposing themselves to risk.
SGS strives to provide certainty. It positions itself as a partner with expertise in product safety and testing. "We're always here to advise on all the different changes taking place," says Jennifer Dwyer, assistant marketing manager. "It's about having a good understanding and being a source to help you identify how to best mitigate your risks." A testing organization will ask what regulations a distributor wants to comply with (CPSIA, California Prop 65, etc.), and then determine the proper amount of coverage to ensure protection (see sidebar). "If you're over-testing," Dwyer says, "you're spending more money than you need to. If you're under-testing, you're putting your product at risk."
"Inside the Lab
Distributors who don't test their products are playing with fire. Here in the SGS flammability lab, it's more than just a metaphor. Test Engineer Bill Booth grabs a pink cotton bag from Prime Line (asi/79530), but before he gets his pyro on, he must measure. He draws a measuring tape diagonally across the bag. This is the longest axis of the product, the measure of which determines the burn rate under ASTM toy guidelines. Booth then takes a burning paraffin wax candle, places the bag in a vented metal hood and sets it aflame. (No flamethrowers here. Or at least none easily accessed by prying media types.) The bag catches fire and begins a slow burn along one of the corners.
You want it to burn slowly to let the child get away from the flame," says Booth, checking his watch for the 60-second time limit. Once time is up, he extinguishes the flame and measures again. The singe marks have hardly made a dent across the greatest expanse of material, and falls well under the .1 inch/second burn rate limit. This bag passes easily.
The flammability test seems relatively primitive, but the same can hardly be said about the analytical and chemical testing done at the facility. It's here where the ultimate determination about lead and phthalate content are made. Most products require what Assistant Laboratory Manager Christina Crimi terms "wet chemistry." She throws on a pair of blue nitrile gloves and demonstrates. Grabbing a flat razor blade, she scrapes the logos off another drawstring bag and a scrambler puzzle onto pieces of paper – one for each color in the logos. From here, the scrapings will be weighed, dissolved in nitric acid, boiled on a hot plate (or in a substrate microwave), filtered and diluted up to volume. Finally, they will be placed in the ICP-OES – a mass spectrometer that measures the presence of lead and any other heavy metals.
That's the traditional way to analyze a product for lead, but not the only way. The SGS lab boasts a new benchtop HDXRF unit – "not a gun," says Crimi, correcting a visitor. The differences are significant. XRF test guns aren't nearly as sensitive and cannot measure surface coatings. The new HD unit, on the other hand, is certified under the CPSIA to measure lead in surface coatings. (Though it can measure substrates too, the CPSC has not updated the test method regulations yet.) It is also a nondestructive method, which saves on sample costs – and helps justify the $70k-$80k price tag for the unit.
Testing is simple. The product slides under the lenses, a few mouse clicks set it up, and six minutes later the results emerge for a host of metals. "As long as it's calibrated to whatever element you want to look for," says Crimi, demonstrating the machine, "that's what it scans for." Many manufacturers, for example, are substituting cadmium for lead in their products because it's cheaper. To search just for lead would be to ignore a potential problem.
The test results are where SGS earns its money. After the tests are completed, Crimi and others conduct a technical review to compile the data and analyze the results. "Test results are the most important thing that comes out of the lab," she says. They show if there was a failure and where it occurred. It might be an interim failure, where just one of the components is at fault, and not the whole product. From there, it's on the client (distributor, supplier or otherwise) to act accordingly. SGS can make suggestions, but ultimately it is just the messenger.
In the Future
The CPSIA was a game-changer that completely transformed the product testing field. While subsequent developments lack the same impact, they still certainly matter. States are creating their own levels of compliance, in very much the same vein that California has done in the past with bills like Prop 65.
E-commerce solutions enable buyers to purchase from all over the globe – and force e-tailers to juggle myriad amounts of standards, both domestically and abroad. In addition, manufacturers are moving away from China to other countries.
"The standards remain the same," Dwyer says, "but because China has had to deal with manufacturing for international standards for so long, companies there might be more familiar with what's required for international markets than some of the new countries that are getting involved." Future areas of concern include magnets and increasing use of electronics in children's products.
In the vein of verifying claims, SGS is making an aggressive expansion into sustainability. The company can run eco assessments that actually determine – by looking at the sourcing of raw materials, energy expenditures, transportation, etc. – if a green product is producing a beneficial environmental impact. SGS has even created its own green certification mark.
"Greenwashing was a big concern," Dwyer says. "We're actually putting some feet behind it to say we tested every part of this process, and our clients can prove a reduction in the carbon footprint."
It's the very foundation that SGS – and the whole product testing industry – has built itself on: a desire for proof.
E-mail: firstname.lastname@example.org. Twitter: @CJ_Wearables