FAQFAQ   SearchSearch   MemberlistMemberlist   UsergroupsUsergroups   RegisterRegister   ProfileProfile   Log in to check your private messagesLog in to check your private messages   Log inLog in 

Q.5 RFC Component v. Unit and 3rd party testing

 
Post new topic   Reply to topic    Fashion-Incubator User Forum Forum Index -> CPSIA Request for Comments
View previous topic :: View next topic  
Author Message
Eric H
Site Admin
Site Admin


Joined: 02 Feb 2007
Posts: 169
Location: NM Albuquerque

PostPosted: Sun Dec 21, 2008 12:05 pm    Post subject: Reply with quote

Ah, this is the big one, isn't it? I have a theory that the lack of control over their contractors is probably part of what caused the big recalls of 2007.

You have a problem first of making sure the contractor isn't substituting components. They either have to supply tested components, and you have to have some check on that, or you have to supply everything to them and make sure they don't shade on you. I suppose if you're working with foreign contractors, you're going to have them do all of the sourcing. And here your troubles begin....

So I suppose if you did the sourcing, then you need to check the component testing. If they do the sourcing, you are still responsible for the component testing as the manufacturer. So what do you trust them to do? Heck, given enough time, I'm sure I could generate a lab test from Bureau Veritas in pdf format that shows fishing weights tested lead-free. So how do you trust your contractors when they are sourcing? And how does a regulator trust you to do due diligence on this point? I suppose you could specify the testing lab, but then how do you know that they aren't using ringers for test purposes? And then how do you keep from exposing your entire supply chain from everyone else in the market?
Back to top
View user's profile Send private message
Vesta
Renewing Member
Renewing Member


Joined: 23 Dec 2005
Posts: 668
Location: TX Austin

PostPosted: Mon Dec 22, 2008 3:10 pm    Post subject: Reply with quote

Yeah, I'm sure you're right about this being the root of the problems in 2007. Obviously, if Mattel made all of their toys at a company-owned factory, there would never be lead introduced into the process (or brought onto the factory grounds, for that matter).

So either you source and arrange for the component parts to be sent to your factory (which is just not how it's usually done, on a large scale - that's part of the joy of having a complete package provider).

Or you spot check finished units for compliance. And you pull units to check from your TOPs, not from samples provided for testing. (sigh)

Honestly, I can't believe Mattel wasn't doing this already. Lazy. Even we do this.
Back to top
View user's profile Send private message
Eric H
Site Admin
Site Admin


Joined: 02 Feb 2007
Posts: 169
Location: NM Albuquerque

PostPosted: Mon Dec 22, 2008 7:12 pm    Post subject: Reply with quote

TOP?
Back to top
View user's profile Send private message
Esther
Moderator
Moderator


Joined: 17 Mar 2006
Posts: 1707
Location: ID Spudville

PostPosted: Tue Dec 23, 2008 8:52 am    Post subject: Reply with quote

I don't know where the Mattel break down happened. I suspect it is because the approved factory did a bait and switch. A common problem in China, where factory workers are taught to lie during inspections and only a small portion of an order is produced in the approved factory.

As far as toys go, batch testing by a third party *MAY* solve some of this problem. But again, if only a portion is produced in the approved factory, it would be difficult, if not impossible, to test the rest because you may not know where it is. Mattel would be stuck with the unenviable task of testing batches (what determines a batch?) after it's all produced and before delivery.
Back to top
View user's profile Send private message Send e-mail Visit poster's website
Vesta
Renewing Member
Renewing Member


Joined: 23 Dec 2005
Posts: 668
Location: TX Austin

PostPosted: Tue Dec 23, 2008 10:28 am    Post subject: Reply with quote

Sorry, Top Of Production. When contracting out production, one should receive the first pieces off the production run (one of each SKU), made with the final components, by the actual production process to be used for the full run. It's the last chance to catch a problem before the QC inspection on the finished products.
Back to top
View user's profile Send private message
Melissa McKeagney
Guest





PostPosted: Sun Dec 28, 2008 9:45 am    Post subject: Reply with quote

This is the hardest question for me, because I don't contract out, and have no experience with the manufacturing process outside my own basement.

What about randomizing your testing. Instead of pulling the first few from a production run, you pull and spot check somewhere down the line. That way if they have substituted some component for another, you ought to be able to tell from a visual check of your sketch sheet swatches whether anything has been substituted.

As for toys, or other products, this might be harder to determine. Whether a certain paint has been swapped for another, it seems to me it would be difficult to tell without doing unit testing. But, if you did do unit testing on one of the first few from the production run, and then later on a switch was made, unit testing wouldn’t have made that product any safer. It really comes down to random quality control, and using a contractor that is trustworthy.

What about having an exemption for certain countries where this has not been a problem, and random unit testing for places that have run into problems with lead, ie. China. In other words, there is no historical reason for not trusting products made in Europe, Japan, the US, and Canada, etc., but we do have reasons for not trusting products made in China and some other South East Asian Countries. So, while you can get products made cheaply in those countries, the manufacturer must pay a certain price, ie random unit testing for using contractors in those countries.

Melissa
Back to top
Alison Cummins
Official Archivist
Official Archivist


Joined: 17 Dec 2005
Posts: 2266
Location: Canada QC Montreal

PostPosted: Tue Dec 30, 2008 2:52 pm    Post subject: Reply with quote

(Jen, you are the manufacturer; you order goods and have them shipped directly to your contractor.)

In theory, you have fewer worries than someone who relies on their contractor to source. However, as Eric points out:

Quote:
You have a problem first of making sure the contractor isn't substituting components. They either have to supply tested components, and you have to have some check on that, or you have to supply everything to them and make sure they don't shade on you.


(Emphasis mine.) As in, contractors have been known to divert high-quality materials and substitute cheaper ones.

While your contractor would never do that, CPSIA can't contain a clause such as "... of course, Jen doesn't need to verify that her contractor hasn't substituted materials because they have such a good and trusting relationship." Or even "people who trust their contractors can save money by not verifying, and they will not be liable or accountable for the lead or phthalate content of their products." It gets back to how do you know your contractor isn't shading on you, and how do you communicate that knowledge meaningfully. CPSIA has come up with an answer: test what you get back from your contractor so you can see for yourself. And they have issued a challenge: OK, if you aren't good with that solution, how do you propose to communicate that your goods meet standards?
Back to top
View user's profile Send private message Send e-mail Visit poster's website
J C Sprowls



Joined: 25 Mar 2006
Posts: 2006

PostPosted: Tue Dec 30, 2008 6:39 pm    Post subject: Reply with quote

Actually, there is a real risk - low, though it may be.

There are times that a contractor managing a customer's inventory can make mistakes. An example might be more applicable to small components (e.g. zippers, non-branded buttons, fusible, etc.).

If the warehousing area isn't well managed, it's a possibility that someone else's buttons might be used on someone else's order. The contractor might discover this error and scurry to replace the buttons as quickly as possible. If they do not have the contact information for the original source, they'll search several other suppliers for a substitute.
Back to top
View user's profile Send private message
Melissa McKeagney
Guest





PostPosted: Tue Dec 30, 2008 6:45 pm    Post subject: Reply with quote

So how do you manage that JC? How do you ensure that the tested component is the one that is actually used?

Melissa
Back to top
Eric H
Site Admin
Site Admin


Joined: 02 Feb 2007
Posts: 169
Location: NM Albuquerque

PostPosted: Thu Jan 01, 2009 8:16 pm    Post subject: Reply with quote

Ha! I knew it. I said, "I could generate a lab test from Bureau Veritas in pdf format that shows fishing weights tested lead-free".

I'm looking at an e-mail from someone who was going to get their logo printed on stainless steel water bottles. They decided to request testing.

Quote:
On December 22 they told me that it came out at 1000 ppm and since that was close - wasn't that okay? After replying NO - they sent me an email on December 24th - GOOD NEWS - bottle passed now - see report. The strange thing was that the report showed the testing being run December 11th - 16th. I questioned the factory on this time line and they gave me some mumbo jumbo about they were just explaining delays, blah, blah, blah. Well for some reason I decided to forward the test report to the testing company's email asking if the results could be verified. Oh, you guessed it ! The testing company told me that the report was false and some data was revised.


So, how far will you trust your contractors to handle this for you?
Back to top
View user's profile Send private message
cinthia
Guest





PostPosted: Thu Jan 01, 2009 8:44 pm    Post subject: testing Reply with quote

Hi Eric -
I wrote that email - let me follow up. I spoke with the testing company branch in the USA - and they suggested that I open an account with them under my company name. Since I'm paying for all this testing anyway - the factory will submit the samples to the local branch but the results will only be sent to me - not to the factory.
Back to top
J C Sprowls



Joined: 25 Mar 2006
Posts: 2006

PostPosted: Thu Jan 01, 2009 9:44 pm    Post subject: Reply with quote

Melissa McKeagney wrote:
So how do you manage that JC? How do you ensure that the tested component is the one that is actually used?


That's the rub. With this new legislation, you - the sponsor of the job - need to come up with an effective strategy to communicate and manage these scenarios.

If it were me. I'd be on-site during the production run. I'd assist with intake processing of the goods, spreading, approve the TOP sample, and then support the QA and out-take processes (e.g. bag, tag, fold, etc.)

My contractors are a phone call away, right now. I haven't yet run into problems with primary components (i.e. fabric/marker), I have had a few last-minute phone calls about labels or thread on backorder or some little nits like that. It's busy work; but, it needs to be done in order to keep the project on the rails.

Customers always try to cheap out in this area. And, it always, always bites them in the tucchus. My theory: give them enough rope to hang themself and demonstrate the value in having an on-site presence.
Back to top
View user's profile Send private message
Esther
Moderator
Moderator


Joined: 17 Mar 2006
Posts: 1707
Location: ID Spudville

PostPosted: Fri Jan 02, 2009 8:59 am    Post subject: Reply with quote

Quote:
If it were me. I'd be on-site during the production run. I'd assist with intake processing of the goods, spreading, approve the TOP sample, and then support the QA and out-take processes (e.g. bag, tag, fold, etc.)


Difficult, if not impossible, to do in an overseas factory. I agree with you on this point though.
Back to top
View user's profile Send private message Send e-mail Visit poster's website
Kathleen F.
Site Admin
Site Admin


Joined: 08 Sep 2005
Posts: 9509
Location: NM Albuquerque

PostPosted: Fri Jan 02, 2009 9:04 am    Post subject: Reply with quote

J C Sprowls wrote:
If it were me. I'd be on-site during the production run. I'd assist with intake processing of the goods, spreading, approve the TOP sample, and then support the QA and out-take processes (e.g. bag, tag, fold, etc.)

NOTE: JC isn't doing kid's products.

Not everyone is going to have the option of hanging out in someone's shop either due to logistics, location etc. Likewise, having a client hanging about causes disruptions, getting in the way and lastly, is an insurance liability. Personally, it'd annoy me to have a client disrupting the work flow, it's disorienting to staff -and me.
Back to top
View user's profile Send private message Send e-mail Visit poster's website
Display posts from previous:   
Post new topic   Reply to topic    Fashion-Incubator User Forum Forum Index -> CPSIA Request for Comments All times are GMT - 6 Hours
Page 1 of 1

 
Jump to:  
You cannot post new topics in this forum
You cannot reply to topics in this forum
You cannot edit your posts in this forum
You cannot delete your posts in this forum
You cannot vote in polls in this forum


Powered by phpBB © 2001, 2005 phpBB Group