Q.7 RFC Component v. Unit and 3rd party testing

[Eric H]

The table of contents for all the questions in the RFC, including an explanation of what an RFC is can be found at Introduction and Table of contents: RFC Component vs unit and 3rd party testing

This section deals with the seventh question which is:

[Eric H]

This is one area where component testing by suppliers (or third-party testing provided by suppliers) can be a clear advantage over unit testing. Cotton cloth is inherently lead and phthalate-free. Dyes may be. If a manufacturer consistently chooses the same cotton cloth and dyes, and all are tested, the lot-to-lot variation is insignificant and irrelevant.

I foresee a "reasonable test" regime in which the inputs are listed:

* Cotton cloth - lead- and phthalate free by supplier test (or exempt from testing)
* Polyester thread - lead- and phthalate free by supplier test (or exempt from testing)
* Fusible - lead- and phthalate free by supplier test
* Buttons - lead- and phthalate free by supplier test
* Zipper (or other hardware) - lead- and phthalate free by supplier test

Should manufacturer, item, lot # be tracked for each of those? On one hand, the manufacturer and part number are proprietary. On the other hand, perhaps you need to create your own database that ties your own lot # to their lot numbers. A database may be as easy as a spreadsheet or even a set of note cards. It may be as sophisticated as some of the PLM/PDM software packages. Either way, managing this information is going to be much less expensive than paying for the tests yourself, and some would argue that they would be safer.

They would be safer because a single button may be mostly lead, but as a percentage of the total mass of the garment, insignificant and well under the legal thresholds. Being legal won't matter much when a child swallows it. By testing each component separately, the entire garment is guaranteed to be compliant as well as inherently safe.

[Vesta]

Agreed. This is related to the previous question. I do think we should prominently mention your last point. It's a big flaw with the unit testing strategy, from the perspective of accomplishing the goals of the law.

[jen m]

I agree too. When I spoke with the testing facility last week he explained something similar.